Under current law, limited partners who materially participate in a partnership's business are not subject to self-employment tax. Members of an S corporation who materially participate in the S corporation's business are subject to self-employment tax only on "reasonable compensation" received in their capacity as an “employee”. These individuals are also exempt from the 3.8% … Continue reading All You Need to Know about the 3.8% Medicare / Net Investment Income Tax & how Pres. Biden Will Expand Who Pays It
COVID-19 restrictions have severely limited services at US embassies and consulates around the world. As a result, renouncing one’s US citizenship has become very difficult, and in many cases, just about impossible at the current time. This gives individuals more time to make sure they have properly planned for expatriation. It's a big step. I … Continue reading Renouncing One’s US Citizenship: More Audits, Virtual Currency, CLN & Travel
The ‘‘Ultra-Millionaire Tax Act of 2021’’ (the “Act”) was proposed by Democratic Senators Elizabeth Warren and Bernie Sanders on March 1 2021. Like all other tax proposals I have seen in my over 35+ years of tax practice, once the bee is in the bonnet, legislation will inevitably, inexorably, eventually blossom and flourish. The Act … Continue reading Senator Warren’s Proposed Wealth Tax and the 40% Tax Hit on Expatriation
Looking at Mr. Biden’s tax proposals and now faced with his win of the presidency, coupled with Democrat control of the House, Americans abroad are in for a rough time. This is especially true for anyone considering giving up US citizenship or long term permanent residency (LTR). Those thinking about expatriation must take immediate action … Continue reading Mr. Biden’s Tax Plans – Serious Pain in Store for those Expatriating, Pain for Americans Abroad…. And Others!
It’s been awhile since I have blogged about our friend, Mr. FBAR. For those of you who are not familiar with his nickname, you may know him by his more formal moniker “Report of Foreign Bank and Financial Accounts” (FinCEN Form 114). He springs from Title 31 of the Bank Secrecy Act (not the Internal … Continue reading FBAR “Willfulness” – Fifty Shades of Gray
I recently spoke on the US tax issues faced by the holder of the green card. To be or not to be such a holder? The podcasts (links below) may help you decide. The podcasts were made with John Richardson, a US and Canadian attorney. John, who is based in Canada, has seen his fair … Continue reading Getting a Green Card – Is it Really Worth It?
In the face of the corona virus, just about everyone I know has been working from home for quite some time. Home can be Stateside or overseas. Many are now asking if they are entitled to take a tax deduction for their “home office”. Here’s everything you need to know. The home office tax break … Continue reading COVID-19: Can I Take a Home Office Deduction?
Before delving into the nitty gritty, let me start with a disclaimer. I am not an immigration specialist and this post does not address, other than in a very general manner, immigration issues associated with surrendering a green card at the border. Today’s blog post examines the US tax issues that surround relinquishing the green … Continue reading Surrendering a Green Card at the Border – COVID-19, Stuck Abroad, “Forced” to Surrender Green Card?
Americans working abroad may be eligible to exclude certain foreign earned income (wages, compensation for services) from US taxable income under the rules governing the Foreign Earned Income Exclusion (FEIE). In addition they may be able to exclude certain amounts paid for foreign housing using the Foreign Housing Exclusion (FHE). Both of these benefits are … Continue reading Section 911 FEIE: IRS COVID-19 Relief in Meeting the Bona Fide Residence or Physical Presence Test
Please pass this along to your friends and colleagues who may have an interest. The International Business and Structuring Association is hosting an event where I, along with other industry leaders, will be covering the unique challenges and opportunities faced by businesses and investors engaged in cross-border transactions between the US and UAE. I hope … Continue reading Business & Investment Structuring Between the USA and UAE