PFICs – The Fairytale Definition That Lives Happily Ever After…

I was hoping that tax reform would have done away with, or at least modified, the troublesome provisions surrounding the PFIC or so-called “Passive Foreign Investment Company”.  This was not to be and it prompted me to review the PFIC rules and count the ways they cause trouble! What is a PFIC? A PFIC is … Continue reading PFICs – The Fairytale Definition That Lives Happily Ever After…

PART II – Forms W-8BEN & W-8BEN-E: What Are They Used For? Which One Must I Complete?

Part I of this blog post explained how Form W-8BEN is used for so-called Chapter 3 income tax withholding purposes covering topics such as the types of income subject to US-source withholding when paid to a foreign (non-US) person; exemptions, length of time for validity of the Form.  It also provided an overview of how … Continue reading PART II – Forms W-8BEN & W-8BEN-E: What Are They Used For? Which One Must I Complete?

Newest Targets: “Enablers” and “Cryptocurrencies”

Over the summer, I blogged about the newly formed “Joint Chiefs of Global Tax Enforcement”, or the “J5”, for short.  Five countries form this international coalition: Australia, Canada, the Netherlands, the United Kingdom, and the United States.   The goal of the J5 is to combat transnational tax crime through increased collaboration; in other words, these … Continue reading Newest Targets: “Enablers” and “Cryptocurrencies”

Before You Think of Becoming an “American Abroad”, Read This….

I was recently asked about the tax problems faced by Americans who move overseas.  Unfortunately, there are many US tax difficulties faced by Americans abroad. In order to make some sense of this vast topic, let's put the major problems into several basic categories.  Once aware of the problems lurking out there, you can get … Continue reading Before You Think of Becoming an “American Abroad”, Read This….

Form 8938: How This IRS FATCA Weapon is Failing

On July 5, 2018, the Treasury Inspector General for Tax Administration ("TIGTA") issued a final audit report covering the enforcement efforts of the US Internal Revenue Service (IRS) of the “Foreign Account Tax Compliance Act” (the infamous "FATCA").  Readers may recall that FATCA was enacted in 2010, but it has been a very rocky road … Continue reading Form 8938: How This IRS FATCA Weapon is Failing

Too Little, Too Late: Fixing the Fraudulent Tax Return

Sometimes an individual will come to me with a pesky problem – they have filed a tax return, but it fraudulently omitted income. Typically, a lot of income.  Typically, from foreign sources.  Always, in hopes the omission will go unnoticed by the IRS.  The thinking is along the lines that since the omission involves foreign … Continue reading Too Little, Too Late: Fixing the Fraudulent Tax Return

Confused Yet? W-8BEN, W-8BEN-E, Foreign ITINs and Dates of Birth

Compliance with the Foreign Account Tax Compliance Act (“FATCA”) enacted 8 years ago, has resulted in a plethora of new US tax reporting requirements, forms and rules.  Unfortunately, all of these continue to evolve and become more and  more complex with the passage of time.  The year 2014 marked a significant year for the Form W-8BEN, a … Continue reading Confused Yet? W-8BEN, W-8BEN-E, Foreign ITINs and Dates of Birth

Jail Time for Plastic Surgeon Hiding Money in Dubai

This FBAR case hit close to home. In fact, it hit home! The Department of Justice proudly announced that it flushed out a Beverly Hills plastic surgeon hiding money in Dubai and got him sentenced to one year and one day in federal prison. Marc Edward Mani, 50,  will serve jail time for failing to … Continue reading Jail Time for Plastic Surgeon Hiding Money in Dubai