Virginia La Torre Jeker, J.D. — US tax matters affecting international clients
Taxpayers have often struggled with shifting tax filing deadlines and complex IRS penalty calculations. But if some of those filing deadlines were legally postponed by an act of Congress, certain penalties and refund interest may have been incorrectly calculated by the IRS, entitling impacted taxpayers to relief. A recent federal court case may offer some … Continue reading Kwong Case: IRS May Owe You Money, Cut Penalties
In a stark reminder of the complexities and pitfalls of renouncing U.S. citizenship, a federal grand jury in the Western District of Texas recently indicted Justin Ryan Schmidt on multiple tax-related charges. Mr. Schmidt, a Cayman Islands national, is a former U.S. citizen and cryptocurrency hedge fund manager. He became a naturalized British citizen in … Continue reading BREAKING! Ex-U.S. Crypto Mogul Indicted: The High Cost of Botched Expatriation
Right before the U.S. tax filing season officially opened on January 26, the Internal Revenue Service announced significant leadership changes that have drawn cautious scrutiny from tax professionals. Practitioners with the high-net-worth clients and those who assist Americans living abroad are paying close attention. While IRS leadership transitions regularly occur, the timing and substance of … Continue reading IRS Under Bisignano: Is More Aggressive Offshore Enforcement Coming?
The United States along with over 70 other countries has adhered to the Joint Statement on the OECD’s Crypto-Asset Reporting Framework, “CARF”. CARF is the digital-asset counterpart to the Common Reporting Standard “CRS” that has exchanged bank and securities account data among signatory countries (now well over 100 countries). The United States has formally indicated … Continue reading Offshore Crypto: IRS Steps Closer To Automatic Reporting Under OECD CARF
In her recent Forbes article “Foreign Trusts – How Structure Can Prevent a Million-Dollar Penalty,” Priya Royal emphasizes a core maxim of cross-border tax planning: whenever U.S. persons are part of the “clan,” heightened vigilance is required. The same principle holds true when U.S. situs assets are involved in foreign families or their structures. Global … Continue reading Global Assets, U.S. Persons: Cross-Border Tax Planning Mandatory
It is crucial to understand the differences between Form W-8BEN and Form W-9 when receiving payments from U.S. sources. This is especially so if the taxpayer operates, invests, or maintains financial accounts overseas. Many taxpayers get this wrong, often to their detriment. This article provides the guidance needed to understand which form is required and … Continue reading Forms W-8BEN and W-9: Which to Use, When, and Why Many Get It Wrong
When love crosses borders, tax complexity often follows. I know this from first-hand experience having married a Swiss national almost 4 decades ago. When U.S. citizens marry foreign nationals who are not U.S. tax residents a host of U.S. tax rules can upend marital bliss by causing tax compliance complexities that are often difficult to … Continue reading A Complicated U.S. Tax Life: Foreign Spouses And Community Property
Hello subscribers, global go-getters, expats, and anyone navigating the maze of US taxes abroad! I've got some exciting updates that'll make your financial life smoother and your dreams of living overseas a whole lot less taxing. First, I just rolled out a complete refresh of my flagship US Tax Primer for American Expatriates Worldwide and … Continue reading Exciting Update: Revamped US Tax Primer for Expats & Global Citizens + Must-Watch YouTube Interviews!
On September 19, 2025, the U.S. District Court for the Northern District of Texas upended IRS FBAR enforcement in United States v. Sagoo (No. 4:24-cv-01159, N.D. Tex. 2025). Sharnjeet Sagoo, a U.S. taxpayer with international ties, faced over $1 million in penalties for alleged willful failures of the Bank Secrecy Act requirement to report foreign … Continue reading The Sagoo Case: FBAR’s Reckoning In A Globalized World
Lenders who advance cash to corporations often do so with a clear expectation: the company will repay the principal and will pay interest, and the borrower will report interest income. Yet for U.S. taxpayers the moment of truth comes much later, sometimes years after the money has left the bank—when the IRS, or a court, … Continue reading Corporate ‘Loans’: The Debt v. Equity IRS Challenge And Tax Nightmares
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