Virginia La Torre Jeker, J.D. — US tax matters affecting international clients
The IRS Commissioner Danny Werfel announced some good news for taxpayers at the end of October 2024. The IRS has ended its practice of automatically assessing penalties when a taxpayer voluntarily submits a late Form 3520, Part IV. This form deals with the obligation of U.S. persons to report to the IRS the receipt of … Continue reading Late Form 3520 Foreign Gifts And Bequests, Good News From IRS
The IRS has established a new pass-through compliance unit within its Large Business and International division, as announced on October 22, 2024. This unit aims to tackle “complex financial arrangements”, targeting high-net-worth individuals and entities that use partnerships, S-corporations, and trusts to reduce their tax burdens. Funded by the Inflation Reduction Act, the initiative seeks … Continue reading IRS Just Launched Pass-Through Compliance Unit: Heightened Focus on Trusts Including Foreign Foundations
Tax penalties can be a harsh reality for many taxpayers, especially those dealing with complex international tax obligations. The IRS imposes penalties to encourage compliance and deter negligence. This article provides a general overview of commonly encountered tax penalties, and then delves into the often-misunderstood penalty relief, "reasonable cause.” Overview Of Tax Penalties Tax penalties … Continue reading IRS Tax Penalty Forgiveness: Challenge Of Proving “Reasonable Cause”
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
As indicated in its responses this summer to several key recommendations from the Taxpayer Advocate Service, the IRS is making strides towards enhancing the taxpayer experience. Among these, significant attention is being given to improving services for international and overseas taxpayers, a group that has faced unique challenges and severe penalties. This article highlights IRS responses … Continue reading IRS Commitment To Assist International And Overseas Taxpayers
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
My article copied below, first appeared on Forbes June 11, 2024 – link here. It explains the important rules to know when IRS comes calling to review prior filed tax returns and assess additional taxes. How long can the IRS come after a taxpayer for tax errors or worse? The tax statute of limitations can … Continue reading How Long Does The IRS Have To Catch Your U.S. Tax Mistake? 6 Scenarios
My article copied below, first appeared on Forbes June 3, 2024 – link here. Follow me on Forbes - it's free and your gateway for easy to understand US international tax coverage. I’ve got 40 years of tax experience and am very careful with my blog posts to ensure accurate information is being provided. Just … Continue reading U.S. Tax: 4 Tips For Americans Receiving A Foreign Inheritance
My article copied below, first appeared on Forbes May 11, 2024 – link here. It provides some important tax tips for those in a US/non-US citizen mixed marriage! Follow me on Forbes for easy to understand US international tax coverage. I’d loved to be your “go-to” person when it comes to US tax issues impacting Americans … Continue reading No U.S. Tax Honeymoon When Americans Marry Non-U.S. Citizens
My article copied below, first appeared on Forbes May 11, 2024 - link here. Follow me on Forbes for easy to understand US international tax coverage. I'd loved to be your "go-to" person when it comes to US tax issues impacting Americans abroad or foreign persons with any US connection. The US always finds a … Continue reading U.S. Tax-Savvy Gifting By Foreigners To U.S. Persons
Virginia - US TAX TALK 