Virginia La Torre Jeker, J.D. — US tax matters affecting international clients
Purchasing or owning real estate property overseas can be an exciting investment opportunity, but for U.S. persons, it comes with significant tax and reporting obligations. Foreign persons becoming U.S. tax residents (e.g., obtaining a green card) may already own overseas properties and should be aware of the U.S. tax issues they will face at the … Continue reading Owning Real Estate Property Overseas: 9 Key U.S. Tax Issues
The Department of Justice and the Internal Revenue Service have recently reaffirmed their strong commitment to pursuing offshore tax evasion through the use of powerful investigative tools. One such tool is the IRS John Doe Summons. On Dec. 23, 2024, the United States District Court for the Southern District of New York granted the IRS authority … Continue reading Offshore Tax Evasion: U.S. Clients Of Trident Trust Target Of IRS John Doe Summons
Representative Darin LaHood just introduced on December 18 the Residence-Based Taxation for Americans Abroad Act, aiming to modernize the US tax system for Americans living overseas. This proposal seeks to shift from the current citizenship-based taxation—which taxes US citizens on their worldwide income regardless of residence—to a residency-based system. The existing US tax framework has … Continue reading Breaking! Residence-Based Taxation for Americans Abroad May Become Reality
The Financial Crimes Enforcement Network, FinCEN Form 114, Report of Foreign Bank and Financial Accounts, is a crucial yet frequently misunderstood requirement for U.S. persons with foreign financial accounts. The FBAR may be familiar to many Americans living abroad, but it remains largely unknown to many U.S.-based individuals who might still have an obligation to … Continue reading Cracking The Code On FBAR Penalties: IRS Collection Hurdles Explained
Many people face the dilemma of what to do with old tax returns and supporting paperwork, often wondering when it’s safe to discard them. However, determining the right time can be tricky, especially for taxpayers with foreign assets. Those with overseas financial interests must pay particular attention for several reasons, including expanded statutes of limitation … Continue reading IRS Tax Records, Foreign Assets: When (And What) To Keep Or Toss
The Report of Foreign Bank and Financial Accounts (FinCEN Form 114) commonly called the FBAR is a crucial reporting requirement for US persons (citizens, green card holders and those meeting the substantial presence test) with foreign financial accounts. With the deadline for the 2023 FBAR set for October 15, my Forbes article provides information to … Continue reading Need an FBAR Escape Hatch?
A recent decision from the 11th Circuit in United States v. Isac Schwarzbaum brings a major development in FBAR (Foreign Bank Account Reporting) penalties and their relationship with the Eighth Amendment's Excessive Fines Clause. The court's holding that FBAR penalties are subject to this constitutional protection under the Excessive Fines Clause is significant, offering taxpayers … Continue reading 11th Circuit Holds FBAR Penalties Are Subject to the Excessive Fines Clause: A Significant Taxpayer Weapon
Navigating the labyrinth of overseas investments can be particularly challenging for American investors. The landscape is often littered with enticing sales pitches from expat investment advisors who, more often than not, lack a deep understanding of U.S. tax laws. While it’s true that investments in certain offshore jurisdictions might not incur local taxes, significant and … Continue reading Offshore Investments, U.S. Tax Traps: What Every American Must Know
My article copied below, first appeared on Forbes July 2, 2024 – link here. Scams have become increasingly more convincing, posing significant financial risk to vulnerable individuals, especially the elderly. Financial security arrangements should be implemented, but when global financial assets or multi-nationals are involved, the U.S. tax issues can get complicated and require extra diligence. … Continue reading 3 Ways To Safeguard Finances Of The Vulnerable, Yet Navigate U.S. Tax
My article copied below, first appeared on Forbes June 19, 2024 – link here. It explains the important U.S. tax rules to know before getting (or keeping) a green card. Unfortunately, the U.S. government never explains these rules as part of the green card application process! In all my years of tax practice, I have … Continue reading U.S. Tax – Think Carefully Before You Get (Or Keep) A Green Card
Virginia - US TAX TALK 