Americans Abroad: Separate But (Not) Equal

I will be posting here a series of eight related videos which discuss the premise that the United States is imposing a separate and more punitive tax system on U.S. dual citizens who live in (and are tax residents of) other countries. The videos were motivated by recent posts by Toronto lawyer John Richardson and … Continue reading Americans Abroad: Separate But (Not) Equal

Do You Have Foreign Life, Sickness, or Casualty Insurance? A Foreign Annuity Contract? Excise Tax / FBAR / Form 8938….

Many US persons living abroad have foreign life, sickness or accident insurance or a foreign annuity. Yet, only a handful have any knowledge of the US Foreign Insurance Excise Tax provisions affecting these policies.  Foreign asset information reporting may also apply.  Here's what you need to know! Foreign Life Insurance Generally, an excise tax of … Continue reading Do You Have Foreign Life, Sickness, or Casualty Insurance? A Foreign Annuity Contract? Excise Tax / FBAR / Form 8938….

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”

Your Children, Kiddie Tax and US Tax Reform – Tax, Tax, Tax the Kiddies!

Giving a significant amount of investment assets to one’s children used to be a popular tax strategy, since it permitted the income earned on the investment to be taxed at the child’s presumably lower tax rate. Congress, in its kind-hearted way enacted the so-called “kiddie tax” in 1986 to prevent parents from abusing this strategy. … Continue reading Your Children, Kiddie Tax and US Tax Reform – Tax, Tax, Tax the Kiddies!

Happy New Year – US to be Blacklisted as a Tax Haven?

Bloomberg reports that next year, the US may be put on the Organization for Economic Cooperation and Development’s (OECD) “blacklist” of tax haven countries alongside such notables as Guam and Trinidad and Tobago.  The move comes as numerous countries continue to question the United States’ adamant refusal to participate in the international information exchange program, … Continue reading Happy New Year – US to be Blacklisted as a Tax Haven?

US Tax Disaster – Investing in Offshore Funds, Life Policies, Portfolio Bonds

What Every Overseas American Investor Must Know …. Many American investors are confused by sales pitches of expat investment advisors who are most often completely unfamiliar with US tax laws. While it is true that no tax may be payable in the fund's jurisdiction (Isle of Man, Guernsey or the UAE, for instance), significant US … Continue reading US Tax Disaster – Investing in Offshore Funds, Life Policies, Portfolio Bonds

PFICs – The Fairytale Definition That Lives Happily Ever After…

I was hoping that tax reform would have done away with, or at least modified, the troublesome provisions surrounding the PFIC or so-called “Passive Foreign Investment Company”.  This was not to be and it prompted me to review the PFIC rules and count the ways they cause trouble! What is a PFIC? A PFIC is … Continue reading PFICs – The Fairytale Definition That Lives Happily Ever After…

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

FORM 8938: Infinite Statute of Limitations & Everything Else You Need to Know

My prior blog post gave details about how the Form 8938, an important “Foreign Account Tax Compliance Act” (FATCA) enforcement weapon, is currently failing.  IRS enforcement efforts are soon on the upswing.  This is because the Treasury Inspector General for Tax Administration issued a report over the summer pointing out the IRS' failures with regard … Continue reading FORM 8938: Infinite Statute of Limitations & Everything Else You Need to Know

Form 8938: How This IRS FATCA Weapon is Failing

On July 5, 2018, the Treasury Inspector General for Tax Administration ("TIGTA") issued a final audit report covering the enforcement efforts of the US Internal Revenue Service (IRS) of the “Foreign Account Tax Compliance Act” (the infamous "FATCA").  Readers may recall that FATCA was enacted in 2010, but it has been a very rocky road … Continue reading Form 8938: How This IRS FATCA Weapon is Failing