Virginia La Torre Jeker, J.D. — US tax matters affecting international clients
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
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
Henry Seggerman has first-hand experience with this type of situation. Without hesitation, my guess is that he’ll tell you to get the Estate into an IRS Voluntary Disclosure Program (“VDP”). Here is the tale of the unenviable case of the Seggermans! Henry was the son of a prominent New York businessman who passed away. Henry was … Continue reading What if Someone Dies Owning an Undeclared Foreign Financial Account? What Should The Executor & Heirs Do?
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
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
The Financial Crimes Enforcement Network (FinCEN) had earlier issued an announcement reminding of the due date for filing the 2017 FinCEN Form 114, Report of Foreign Bank and Financial Accounts (the notorious “FBAR”). The 2017 FBAR relates to foreign financial accounts held at any time during the calendar year 2017. In line with the change in … Continue reading FBAR “Last Chance” Due Date Soon Here – What to do with Virtual Currency?
A lively discussion is set to drum up support to convince US lawmakers to end America’s increasingly-unpopular “citizenship-based” tax regime. The meeting will take place in London next week. When: Tuesday 18 September 2018 - 17:30 to 19:00 Where: Central London location – to be confirmed upon RSVP (nearest tube: Westminster) Venue: To be provided upon RSVP (nearest … Continue reading Americans Abroad: Sept 18, LONDON – Push to End Citizenship-Based Taxation
The Internal Revenue Service (IRS) reminded taxpayers yesterday that they have until September 28 to apply for the Offshore Voluntary Disclosure Program (OVDP). In March, the IRS announced the program would end on the 28th of this month. The IRS has made clear that it will continue to hold taxpayers with undisclosed offshore holdings accountable after … Continue reading OVDP Ending / IRS To Announce New Procedures
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
Virginia - US TAX TALK 