Am I Being Cynical? Serious Problems Acknowledged -Too Little, Too Late for Taxpayers Outside the US

The Taxpayer Advocate Service (TAS) recently released its 2022 report to Congress.  In one portion of the Report (listed in “Most Serious Problems Encountered by Taxpayers” #10 OVERSEAS TAXPAYERS: Taxpayers Outside of the United States Face Significant Barriers to Meeting Their U.S. Tax Obligations) TAS provided a succinct review of the problems faced by American … Continue reading Am I Being Cynical? Serious Problems Acknowledged -Too Little, Too Late for Taxpayers Outside the US

Overseas Americans: Fast Facts About Amending a US Income Tax Return

Soon enough thoughts will turn to preparing US tax returns for 2022.  Thorough preparation should at least include a review of the tax return filed for the prior tax year. In doing this, it often happens that taxpayers discover an error occurred in filing a prior year’s return.  If an error is discovered, it may … Continue reading Overseas Americans: Fast Facts About Amending a US Income Tax Return

Is the IRS Being Reasonable when it comes to “Reasonable Cause”?

My recent blog post discussed how I approach “streamlined procedure” filings for taxpayers with unreported income, for example, from offshore assets or accounts. Often, the tax noncompliance for such cases involves unfiled international information returns as well.  As discussed in the blog post, I draft the required statement of non-willfulness in such a manner that … Continue reading Is the IRS Being Reasonable when it comes to “Reasonable Cause”?

Foreign Accounts and Assets: How I Approach a “Streamlined” Tax Filing Nowadays

The Internal Revenue Service (IRS) Streamlined Procedures of 2014 are still available for taxpayers with tax noncompliance issues that involve unreported income from a foreign financial asset. The Procedures can help taxpayers who have not filed certain information returns associated with the foreign asset (e.g., Form 8938; Form 5471 pertaining to ownership in a foreign … Continue reading Foreign Accounts and Assets: How I Approach a “Streamlined” Tax Filing Nowadays

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

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

Expatriation – IRS Told to Get Tough and Enforce the Law

The Treasury Inspector General for Tax Administration (TIGTA) recently issued its report “More Enforcement and a Centralized Compliance Efforts Are Required for Expatriation Provisions”, (Reference Number: 2020-30-071, September 28,2020) telling the Internal Revenue Service (IRS) that it needs to do more to make sure that the rising number of US citizens and long term residents … Continue reading Expatriation – IRS Told to Get Tough and Enforce the Law