Virginia La Torre Jeker, J.D. — US tax matters affecting international clients
Everything you need to know about US tax is right here at your fingertips! My primer provides information for overseas Americans and green card holders on US tax obligations including Income Tax, Estate Tax and Gift Tax as well as IRS reporting requirements and State income tax. It also provides detailed information for foreign individuals … Continue reading Tax Primer: US Expats & Foreigners
I have blogged extensively about the “Foreign Account Tax Compliance Act” (FATCA) in the past. Most of my readers know that FATCA was enacted in 2010 but has taken years to implement. The law requires foreign (non-US) financial institutions (FFIs) to report financial accounts owned by US persons (including through entities) to the Internal Revenue … Continue reading The FATCA Goose Lays a Rotten Egg: Treasury Watchdog Lambasts IRS & US Supreme Court Denies Relief
Another court just slammed the Internal Revenue Service (IRS), limiting the “willful” FBAR penalty to $100,000. Another taxpayer victory took place last week in United States v. Wadhan, (Civil Action No. 17-CV-1287-MSK District Court, District of Colorado July 18, 2018). The Wadhan’s failed to file or filed inaccurate so-called FBARs for 2008, 2009, and 2010. … Continue reading Second Court Bars IRS from Assessing FBAR “Willful” Penalty in Excess of $100,000
The Internal Revenue Service (IRS) must be fuming over the recent court decision in United States v. Colliot (W.D. Texas, Austin Division, Case No. AU-16-CA-01281-SS). The case was initiated by the US Government to reduce to judgment outstanding civil penalties assessed against Ms. Colliot for her “repeated and willful failures to timely file” an FBAR for the … Continue reading Court Slams IRS: Can’t Assess More Than $100,000 “Willful” FBAR Penalty
I blogged recently about the fact that mounting court cases have given the stamp of approval for the Government to meet a lower “burden of proof” in demonstrating that a taxpayer “willfully” failed to file an FBAR. The “burden of proof” refers to which party is responsible for putting forth evidence and, the level of evidence … Continue reading FBAR “Willful” Penalty: New Case, Taxpayer “Charged With Knowledge”
Many countries are waking up to the fact that offshore structures, financial instruments, cryptocurrency and other advances in technology, when inappropriately used, are fast outwitting their tax collectors. This wake-up was eventually accompanied by the realization that there is more power in collaboration and in numbers. Who or What is the “J5”? The “Organization for … Continue reading The J5 International Tax Hunt is On….
Many of my readers already know that one’s US passport is in serious jeopardy if a taxpayer has what is called “seriously delinquent tax debt”. First, some brief background on the law and how it particularly affects Americans living and working overseas. I’ll then provide the latest statistics on the passport enforcement efforts since the … Continue reading Passport Revocation Update: Over 436,000 Taxpayers Meet “Certification” Criteria
US tax liabilities and requirements to file US tax and information returns are impacted by community property laws that exist in many foreign countries across the globe. Today’s blog post will examine some of these issues and set the stage for upcoming posts dealing with community property in the international context and how it affects … Continue reading US Tax Perils of International Community Property
Virginia - US TAX TALK 