On March 15, I was delighted to present cross-border tax topics of interest for the Financial Planning Association (FPA). FPA is a well-known membership organization for certified financial planner professionals and those engaged in the financial planning process. It provides its members with practice support, learning, advocacy, and networking. As a tax professional, with 40 … Continue reading Free for You: My Cross-Border Tax Presentation for the Financial Planning Association
Category: Foreign Persons Moving to the USA
Treaty Tie-Breaker: Oh the Pitfalls Beware!
The United States is unique in its approach to taxing individuals who are US citizens or lawful permanent residents (green card holders). Such individuals are taxed on worldwide income regardless of where they may reside. On account of this taxation approach, US citizens and green card holders who live outside of America may be subject … Continue reading Treaty Tie-Breaker: Oh the Pitfalls Beware!
Breathing American Air – Hazardous to your Wealth? (Part II)
Part 1 of this blog post introduced readers to some of the issues surrounding US taxation of foreign persons and discussed the pitfalls of tax ignorance. This 2-part series identifies areas of potential US tax exposure for foreign nationals and examines the questions the foreign person and his advisors should be asking before taking a … Continue reading Breathing American Air – Hazardous to your Wealth? (Part II)
US Residency “First Year Election” and FBAR – The Devil is in the Details
Recently, I presented a webinar for tax pro’s earning CPE credits; the topic involved our favorite character, Mr. FBAR. The FBAR, Form 114, is more formally known as the Report of Foreign Bank and Financial Accounts. The webinar will be available soon as a CPE credit "self-study" program. Send me an email if you wish … Continue reading US Residency “First Year Election” and FBAR – The Devil is in the Details
Caught in the US Tax Trap: PART II How Does a Non-US citizen Become a US “Resident” – Taxed on WORLDWIDE Income?
Last week's blog post looked at one way that a non-US citizen can become subject to US income tax on his or her worldwide income - simply by getting a US green card. Today's post looks at the other way one can fall into the US tax trap. “Substantial Presence” in the US An individual … Continue reading Caught in the US Tax Trap: PART II How Does a Non-US citizen Become a US “Resident” – Taxed on WORLDWIDE Income?
Senator Warren’s Proposed Wealth Tax and the 40% Tax Hit on Expatriation
The ‘‘Ultra-Millionaire Tax Act of 2021’’ (the “Act”) was proposed by Democratic Senators Elizabeth Warren and Bernie Sanders on March 1 2021. Like all other tax proposals I have seen in my over 35+ years of tax practice, once the bee is in the bonnet, legislation will inevitably, inexorably, eventually blossom and flourish. The Act … Continue reading Senator Warren’s Proposed Wealth Tax and the 40% Tax Hit on Expatriation
Business & Investment Structuring Between the USA and UAE
Please pass this along to your friends and colleagues who may have an interest. The International Business and Structuring Association is hosting an event where I, along with other industry leaders, will be covering the unique challenges and opportunities faced by businesses and investors engaged in cross-border transactions between the US and UAE. I hope … Continue reading Business & Investment Structuring Between the USA and UAE
Have you Expatriated or Thinking of Expatriating? IRS Now Looking Closely
On July 19th, the Internal Revenue Service (IRS) through its Large Business and International (LB&I) Division announced six new “compliance campaigns” for taxpayers. Significantly, one of these campaigns targets “expatriation”, and apparently reaches back to those who “expatriated” on or after June 17, 2008. The campaign will be looking at “expatriates” – US citizens who … Continue reading Have you Expatriated or Thinking of Expatriating? IRS Now Looking Closely
House Blocks IRS Free-File Tax Help: Who Cares!
In early April, the House of Representatives passed a bill that would re-design the Internal Revenue Service (IRS). It had a nifty and promising title, the "Taxpayer First Act of 2019". Despite its sweet title, part of the bill would prohibit the IRS from providing taxpayers with free tax preparation software. The for-profit tax preparation … Continue reading House Blocks IRS Free-File Tax Help: Who Cares!
The Foreigner and the Taxman: Are You “Married” for US Income Tax Purposes?
Life gets confusing when you’re an American and you’ve married a “foreigner”. Aside from the cultural and social differences you may encounter, you cannot forget that your US tax situation will now become even more complex. Many of my tax blog posts explain the thorny side of filing US income tax returns, FBARs and various … Continue reading The Foreigner and the Taxman: Are You “Married” for US Income Tax Purposes?