US Person – Made a “Loan” to a Foreign Corporation?

What happens if you make a loan to a foreign (non-US) corporation and the Internal Revenue Service (IRS) later determines that the “loan” should not be treated as a “loan” for US tax purposes?  Instead, the IRS says it should be treated as if you made a capital contribution to the corporation and therefore had … Continue reading US Person – Made a “Loan” to a Foreign Corporation?

Is IRS Finally Seeing the Light on Foreign Information Returns?

Bloomberg Tax - I invite readers to enjoy my recently published article, copied in full below. Reproduced with permission. Published December 3, 2021. The Bureau of National Affairs, Inc. (800-372-1033) http://www.bloombergindustry.com published in Tax Insights and Commentary News, online here.   Various options are available to correct the problem of missing information returns for U.S. … Continue reading Is IRS Finally Seeing the Light on Foreign Information Returns?

Escaping Tax Penalties – “Reasonable Cause” & Reliance on Professional Advice

Today' lesson - Choose your US tax advisor very carefully.  If he or she lacks the US international/foreign tax experience you may need, reliance on the tax advice may not be considered "reasonable," leading to plenty of penalties.  Let's explore! Various civil tax penalties can be assessed when a taxpayer fails to pay the correct … Continue reading Escaping Tax Penalties – “Reasonable Cause” & Reliance on Professional Advice

US Tax Training – Moving Abroad: Tax Impact on Digital Nomads, Remote Workers and Their (Often Overlooked) Employers

Tax pro’s - are you prepared to advise clients who wish to explore foreign work possibilities? So many changes have been wrought as a result of COVID-19, one of the biggest being remote working. As a direct result of the pandemic people are moving or considering it.  COVID-19 has convinced us that having internet access and … Continue reading US Tax Training – Moving Abroad: Tax Impact on Digital Nomads, Remote Workers and Their (Often Overlooked) Employers

Buying Time – International Tax Forms & More…IRS Notice 2020-23 Expands Relief for US Tax Filings, Elections, Payments

On April  9th, the Internal Revenue Service (IRS) issued IRS Notice 2020-23 providing extended tax filing, election and payment deadlines to a generous number of Forms. Generally speaking most tax returns, payments, and elections that are due from April 1, 2020 to July 15, 2020 are now automatically extended until July 15, 2020. This means there is … Continue reading Buying Time – International Tax Forms & More…IRS Notice 2020-23 Expands Relief for US Tax Filings, Elections, Payments

US Citizenship And Worldwide Taxation: Justified?

Tune in to the amazing debate between John Richardson and Edward Zelinsky, two renowned tax and citizenship professionals, taking place on Friday May 17.  Not only is it free,  but viewers will receive an unparalleled education about the major issues surrounding US citizenship, its tax consequences for the typical American abroad and Accidental Americans, effects … Continue reading US Citizenship And Worldwide Taxation: Justified?

Head’s Up! Foreign-Owned Single Member US LLC: Increase in Penalties for Form 5472

My earlier blog post covered some basics about Form 5472, including how the Form helps the US Internal Revenue Service (IRS) learn about foreign-owned businesses in the US and when to audit them, the meanings of certain terms such as what is meant by a “reportable transaction” with a “related party”, and the situation requiring filing … Continue reading Head’s Up! Foreign-Owned Single Member US LLC: Increase in Penalties for Form 5472

US Tax Law to American Abroad – “How Do I Hate Thee, Let Me Count the Ways”

Regular readers of my tax blog will not be surprised by the title of this post and the content it hints at delivering. They likely realize by now that the American person abroad is not looked upon favorably by the US tax laws.  The tax laws look at anything “foreign” with a jaundiced eye when … Continue reading US Tax Law to American Abroad – “How Do I Hate Thee, Let Me Count the Ways”

US Owners of Foreign Corporations – Beware the Downsides

My earlier blog post introduced readers to the concepts of so-called CFCs and PFICs and some of the downsides of owning a "foreign" corporation. It analogized to quicksand simply because it is very easy to be swallowed up in harsh tax results and onerous reporting obligations if planning is not undertaken beforehand. I will remind … Continue reading US Owners of Foreign Corporations – Beware the Downsides

Quicksand! US Owners of Foreign Corporations

It is usually very quick and easy to set up a foreign corporation - say, one in Belize or in the Cayman Islands.  What is not so easy is working one's way through the quagmire of required Internal Revenue Service (IRS) reporting and US  tax obligations simply because you are a US person owning shares … Continue reading Quicksand! US Owners of Foreign Corporations