Global Assets, U.S. Persons: Cross-Border Tax Planning Mandatory

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 →

Corporate ‘Loans’: The Debt v. Equity IRS Challenge And Tax Nightmares

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 →

WEBINAR – Remote Work, Global Teams & U.S. Tax: What Every CPA and EA Needs to Know

Some exciting news. I am presenting a webinar on Monday, July 28 2025. 2 IRS CPE credits. 12:00 PM ET | 11:00 AM CT | 09:00 AM PT 90 MINUTES Hope to see you there. Please share with your colleagues and friends who may have interest in this topic. REGISTER AT THE LINK: https://educatorprime.com/product/remote-work-global-teams-u-s-tax-what-every-cpa-and-ea-needs-to-know WEBINAR … Continue reading WEBINAR – Remote Work, Global Teams & U.S. Tax: What Every CPA and EA Needs to Know →

IRS Tax Penalty Forgiveness: Challenge Of Proving “Reasonable Cause”

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” →

IRS Commitment To Assist International And Overseas Taxpayers

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 →

National Taxpayer Advocate – Pushes for Positive Changes for Americans Abroad

The law requires the National Taxpayer Advocate (NTA) to submit two annual reports to the House Committee on Ways and Means and the Senate Committee on Finance, without any prior review or comment from the Internal Revenue Service. The NTA Report for FY 2025 was just issued and includes various NTA advocacy objectives. Two of the … Continue reading National Taxpayer Advocate – Pushes for Positive Changes for Americans Abroad →

Another Breaking! Farhy Overruled – A Big Loss for Overseas Americans

I have written earlier on the case of Farhy v. Commissioner. There the Tax Court held that the IRS does not have the authority to assess and collect penalties asserted under Internal Revenue Code Section 6038(b). In the Farhy case, the assessed penalties were imposed for failure to file Form 5471, the IRS form required … Continue reading Another Breaking! Farhy Overruled – A Big Loss for Overseas Americans →

Insights For Foreigners: Navigating The U.S. Tax Maze Before Residency

As some of my readers know, I am now a contributor writing on Forbes. My coverage area is US international tax law for overseas Americans and foreigners. My article is copied below. It first appeared on Forbes April 14, 2024 here. Don't miss out on my informative and easy-to-understand US tax content - Follow me … Continue reading Insights For Foreigners: Navigating The U.S. Tax Maze Before Residency →

Taxpayer Wins Again on 5471 Penalty – IRS Cannot Assess

In a holding by the US Tax Court on April 8, 2024, the case of Raju J. Mukhi v. Commissioner of Internal Revenue brought into sharp focus the principle of stare decisis and its implications for tax law. The Tax Court rejected the IRS’ assessment of penalties under Section 6038(b), for failure to file Form … Continue reading Taxpayer Wins Again on 5471 Penalty – IRS Cannot Assess →

To Amend or Not to Amend – That is the Question

Discovered an error in a prior year’s tax return? Everyone is busy preparing US tax returns for 2023. Taxpayers should note that thorough preparation of the current year’s tax return should include a review at least, of the return filed for the prior tax year. (Taxpayers using new return preparers should be wary if … Continue reading To Amend or Not to Amend – That is the Question →