Virginia La Torre Jeker, J.D. — US tax matters affecting international clients
The US Supreme Court just agreed to resolve the split in the circuit courts whether the FBAR $10,000 civil nonwillful penalty is to be applied on a “per account” rather than “per form” basis. By granting certiorari to Mr. Bittner, a taxpayer who petitioned the Court to review his case, we will finally have a … Continue reading US Supreme Court to Decide: FBAR Penalty, $10K per Form or per Account?
Curious about what it means from a US tax perspective if you give up your green card or US citizenship? You really should know BEFORE you take the plunge and apply for that green card or obtain US citizenship. Tax pro's -- Want to expand your client reach by advising and planning with confidence about “expatriation”? … Continue reading Everything You Need to Know: “Expatriation”- Giving up a Green Card (LTR) or US Citizenship
The Treasury Inspector General for Tax Administration (TIGTA) just issued a damning report on FATCA: Additional Actions Are Needed to Address Non-Filing and Non-Reporting Compliance Under the Foreign Account Tax Compliance Act (Report # 2022-30-019 4/7/22), available here. The TIGTA audit was undertaken to evaluate IRS efforts to actually use the reams and reams of … Continue reading Treasury Inspector General Says FATCA is a Big Fat Flop ….So Far
Last week during testimony to the Senate Finance Committee (SFC), US Internal Revenue Service Commissioner (IRS) Charles Rettig stated that Congress needs to provide clear statutory authority in order for the IRS to collect information on cryptocurrency transfers valued over US$10,000. It is believed that such transfers are generally not being reported. Cryptocurrency market capitalization … Continue reading IRS Wants Crypto Information from Foreign Countries
President Biden has an economic agenda and a big part of it is strengthening taxpayer compliance by increasing what must be reported to the Internal Revenue Service (IRS) about client accounts by third party financial institutions and similar entities. The President’s proposal would require information reporting on both business and personal financial accounts. The reporting … Continue reading Pres. Biden: 3d Party Information Reporting to be Increased – Foreign Accounts and Crypto Included
Today’s blog post discusses the overall and international tax gaps, takes a look at the offshore world and how enforcement of the tax laws is faring (hint - not so good). It summarizes some important testimony given on May 11, 2021 by the Honorable J. Russell George, Treasury Inspector General for Tax Administration before the … Continue reading Closing the International Tax Gap: IRS Doing Virtually Nothing With FATCA
Since the passage of the Foreign Account Tax Compliance Act (FATCA) in 2010, we’ve been inundated with mountains of information about this legislation including its implementing Treasury Regulations, Internal Revenue Service (IRS) announcements and notices, reams of articles, books, blog postings as well as a Twitter-verse awash with FATCA-esque tweets. Following FATCA’s roll-out, hordes of … Continue reading FATCA 11 Years Later – US Still the Tax Haven?
There’s a new law on the books and it does not bode well for, among others, those with foreign accounts that have not been properly reported to the Internal Revenue Service. The “Combating Money Laundering, Terrorist Financing, and Counterfeiting Act of 2019” (the “Act”) became part of the reconciled National Defense Authorization Act for Fiscal … Continue reading Your Foreign Bank Records – IRS Now Has Much Easier Access
Merry Christmas to all of my readers and followers who celebrate this special time of year. I hope the joy of the season will follow you into the New Year. Sadly, Christmas won’t be merry for many Americans abroad who are ensnared in the grip of “FATCA,” the notorious “Foreign Account Tax Compliance Act”. Briefly, … Continue reading MERRY CHRISTMAS: FATCA Drops Coal on the Doorstep of Americans Abroad
The Internal Revenue Service (IRS) - starting to see some light with respect to "foreign" pension plans? The US tax issues surrounding foreign pensions and retirement schemes is extremely complex and has vexed tax professionals and US persons abroad for many years. (Read my earlier blog post here). Due to the diversity of such plans, … Continue reading Foreign Pension Plans / Retirement Trusts – Is IRS Seeing the Light?
Virginia - US TAX TALK 