Virginia La Torre Jeker, J.D. — US tax matters affecting international clients
Foreign investors with assets in the United States often encounter complex estate tax rules that can significantly impact taxation of their U.S. assets at death. If the individual is a non-resident, non-citizen of the U.S. (NRNC), the U.S. estate tax applies only to assets situated or deemed to be situated within the U.S. (for example, … Continue reading U.S. Estate Tax Treaties – Help For Foreigners But Not U.S. Citizens
IRS literally just finalized the Code Section 2801 regulations on January 10. These long-awaited final regulations concern gifts and bequests received by a U.S. person from foreign persons who were former U.S. citizens or green card holders who qualified as "long term residents" and were "covered expatriates" at the time of giving up their U.S. … Continue reading BREAKING! Final IRC Section 2801 Regs Issued on Foreign Gifts or Bequests …. Buckle Up…. Rough Ride Ahead
Representative Darin LaHood just introduced on December 18 the Residence-Based Taxation for Americans Abroad Act, aiming to modernize the US tax system for Americans living overseas. This proposal seeks to shift from the current citizenship-based taxation—which taxes US citizens on their worldwide income regardless of residence—to a residency-based system. The existing US tax framework has … Continue reading Breaking! Residence-Based Taxation for Americans Abroad May Become Reality
Roger Ver, an early Bitcoin investor renowned as “Bitcoin Jesus” for his evangelism of cryptocurrency since 2011, now finds himself in a legal maelstrom. Ver, a controversial figure in the blockchain world, was arrested in April 2024 in Spain on U.S. criminal charges stemming from allegations of mail fraud, tax evasion, and filing false tax … Continue reading Bitcoin Jesus Challenges Constitutionality Of Expatriation “Exit Tax”
The Financial Crimes Enforcement Network, FinCEN Form 114, Report of Foreign Bank and Financial Accounts, is a crucial yet frequently misunderstood requirement for U.S. persons with foreign financial accounts. The FBAR may be familiar to many Americans living abroad, but it remains largely unknown to many U.S.-based individuals who might still have an obligation to … Continue reading Cracking The Code On FBAR Penalties: IRS Collection Hurdles Explained
U.S. immigration law assumes that a person admitted to the United States as a lawful permanent resident (green card holder) will live there permanently. Remaining outside the United States for an extended period, may possibly result in a loss of LPR status. Long periods spent outside of America can result in problems upon re-entry at the … Continue reading Surrender Green Card At The Border: Form I-407, U.S. Tax Expatriation
Many people face the dilemma of what to do with old tax returns and supporting paperwork, often wondering when it’s safe to discard them. However, determining the right time can be tricky, especially for taxpayers with foreign assets. Those with overseas financial interests must pay particular attention for several reasons, including expanded statutes of limitation … Continue reading IRS Tax Records, Foreign Assets: When (And What) To Keep Or Toss
The Report of Foreign Bank and Financial Accounts (FinCEN Form 114) commonly called the FBAR is a crucial reporting requirement for US persons (citizens, green card holders and those meeting the substantial presence test) with foreign financial accounts. With the deadline for the 2023 FBAR set for October 15, my Forbes article provides information to … Continue reading Need an FBAR Escape Hatch?
Cybercrime and fraudulent activities continue to evolve and expand. Protecting taxpayers has become an increasingly complex challenge for both governmental authorities and those in the tax profession. Recognizing this, in mid-August the IRS spearheaded the formation of the Coalition Against Scam and Scheme Threats. CASST is an outgrowth of the Security Summit, a public-private initiative … Continue reading Americans Abroad, Tax Scams And IRS’ New Coalition To Combat Tax Fraud
Many taxpayers, especially retirees living abroad, may find themselves in a situation in which their income is too low to meet the threshold for filing a U.S. tax return. Retirees who only receive Social Security income (or small amounts of other additional income), for example, often fall below the tax filing requirement. Understandably, many people … Continue reading Filing A U.S. Tax Return – Even When Not Required – A Very Smart Move
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