Offshore Crypto: IRS Steps Closer To Automatic Reporting Under OECD CARF

The United States along with over 70 other countries has adhered to the Joint Statement on the OECD’s Crypto-Asset Reporting Framework, “CARF”. CARF is the digital-asset counterpart to the Common Reporting Standard “CRS” that has exchanged bank and securities account data among signatory countries (now well over 100 countries). The United States has formally indicated … Continue reading Offshore Crypto: IRS Steps Closer To Automatic Reporting Under OECD CARF →

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 →

Exciting Update: Revamped US Tax Primer for Expats & Global Citizens + Must-Watch YouTube Interviews!

Hello subscribers, global go-getters, expats, and anyone navigating the maze of US taxes abroad! I've got some exciting updates that'll make your financial life smoother and your dreams of living overseas a whole lot less taxing. First, I just rolled out a complete refresh of my flagship US Tax Primer for American Expatriates Worldwide and … Continue reading Exciting Update: Revamped US Tax Primer for Expats & Global Citizens + Must-Watch YouTube Interviews! →

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 →

Substantial Presence: Too Much U.S. Time Means Global Tax—But Exceptions Exist

Many non-Americans underestimate just how easily time spent in the United States can transform them into U.S. taxpayers. Under American tax law, you don’t need a U.S. passport or green card to face very significant IRS tax obligations. Simply spending enough days on U.S. soil may result in being classified as a “resident alien.” That … Continue reading Substantial Presence: Too Much U.S. Time Means Global Tax—But Exceptions Exist →

What Every American Overseas (or Dreaming of Living Overseas) Must Know 2025

Thinking of moving overseas, or already living abroad as an American? One thing you can’t escape is U.S. taxes. In this video, I sit down with Jahtna Hernandez to discuss the unique challenges Americans face under a citizenship-based tax system, and the key rules every expat, retiree, or digital nomad needs to know in 2025. … Continue reading What Every American Overseas (or Dreaming of Living Overseas) Must Know 2025 →

New Self-Employment Tax Risks For U.S. Investors In Global Funds

The U.S. Tax Court decided Soroban Capital Partners LP v. Commissioner (T.C. Memo 2025-52) in May 2025 leaving financial, tax and legal advisors concerned. The court upended assumptions about the self-employment tax exemption for limited partners in hedge funds, and by analogy to venture capital, and private equity partnerships both in the U.S. and abroad. U.S. … Continue reading New Self-Employment Tax Risks For U.S. Investors In Global Funds →

Foreign Stock Options: 6 Things American Expats Should Know

As more Americans take on international roles, stock options have become a key part of the expatriate executive’s compensation package, especially when working for foreign employers. These options offer exciting opportunities to benefit from a company’s growth, but they also come with complex U.S. tax implications that can catch the unwary off guard. Imagine you’re … Continue reading Foreign Stock Options: 6 Things American Expats Should Know →

Unfiled Tax Returns Can Lead To An IRS Action That Costs You Money

With tax filing season in full swing, it’s important to understand what might happen if you do not file a U.S. income tax return. The IRS can, and often will, file a “substitute” return for you and generally, it won’t be favorable. Taxpayers living and working abroad face greater risks with a SFR. The IRS … Continue reading Unfiled Tax Returns Can Lead To An IRS Action That Costs You Money →

Offshore Tax Evasion: U.S. Clients Of Trident Trust Target Of IRS John Doe Summons

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 →