In September 2019, the Internal Revenue Service (IRS) announced new Relief Procedures for Certain Former Citizens that will enable certain individuals who relinquished (or are relinquishing) their US citizenship to come into compliance with their US tax and filing obligations. These lucky individuals will not have to pay the back taxes otherwise owed; nor will … Continue reading IRS “Relief Procedures for Certain Former Citizens” – Hey! What About Green Card Holders?
I have written a series of blog posts about foreign (i.e., non-US) trusts and the US tax issues associated with them including the US tax filing and reporting requirements for each of the different players in the foreign trust scenario (creator or "grantor"/"settlor" of the trust), the trustee; and today, the US beneficiary. One of … Continue reading US Beneficiary of Foreign Trust: Understanding US Tax Filings
For today's post, let me start with the Conclusion! If you expatriate after June 16, 2008 and you fail to file Internal Revenue Service (IRS) Form 8854 (Initial and Annual Expatriation Statement), you DO NOT have continued US income tax liability on your worldwide income. It's that simple. You may have read or heard otherwise … Continue reading FALSE! Failure to File Form 8854 Means Continued Liability for US Tax on Worldwide Income
Transactions now span the globe with the tap of a key on an I-Phone; families are multi-national, with many living in different parts of the world at different stages in their careers and lives; virtual currency has become official legal tender in at least one country, the United States has de facto imposed enforcement of … Continue reading Life Gets Complicated When a Foreign Country’s Laws Impact US Tax
On July 19th, the Internal Revenue Service (IRS) through its Large Business and International (LB&I) Division announced six new “compliance campaigns” for taxpayers. Significantly, one of these campaigns targets “expatriation”, and apparently reaches back to those who “expatriated” on or after June 17, 2008. The campaign will be looking at “expatriates” – US citizens who … Continue reading Have you Expatriated or Thinking of Expatriating? IRS Now Looking Closely
Part I of this blog post examined the importance of the Residency Starting Date (RSD) and how it applied under the Green Card Test. It also pointed out that traps for the unwary can destroy pre-immigration tax planning if one had not correctly nailed down the RSD. Today's post will examine the RSD rules that apply when … Continue reading US Immigrant’s Residency Starting Date – The Devil’s Details – Too Many Days in the USA?
When a foreign individual commences “residency” in the United States for US Income Tax purposes, this date, the Residency Starting Date (RSD), will mark the official date he begins to be taxed on his worldwide income and becomes responsible for various tax information reporting (such as FBAR, Form 5471, Form 8938, to name a few). Commencing on this … Continue reading “Residency Starting Date” – Don’t Leave Home Unless You Understand It!
Today's post looks at the US Internal Revenue Service (IRS) options available to taxpayers residing abroad who need an “Individual Taxpayer Identification Number” (ITIN) to fulfill their US tax filing duties. There are 3 basic options (i) mailing the completed Form W-7, “Application for Individual Taxpayer Identification”, and required identification documents to the IRS (ii) … Continue reading Getting an ITIN When Overseas: Help!
Today's post is a continuation of a series of blog posts dealing with foreign trusts A general overview of the US tax issues surrounding foreign trusts can be found here. When a US person is involved in any way with a foreign trust extra caution is required. Strict US tax filing responsibilities come into play … Continue reading US Tax Filings by US Grantor of Foreign Trust
Quite often, US taxpayers living in a foreign country are faced with tight deadlines for filing their paper tax returns. They are often confused as to how to send these physical documents to the Internal Revenue Service (IRS) and be considered to have sent them in a timely fashion when the foreign (i.e., non-US) post … Continue reading Americans Overseas: Timely Filing of Tax Returns and Other Documents With the IRS