Virginia La Torre Jeker, J.D. — US tax matters affecting international clients
The Internal Revenue Service (IRS) has been examining the possibility of a direct e-filing system. Can you imagine that bypassing tax preparation software or return preparers and direct filing with the IRS may be on the horizon? The IRS’s contemplated plan would enable users to directly prepare and file their tax returns with the U.S. … Continue reading IRS E-Filing Plan: No Solution for the Overseas American
If you or your clients are really (really) wealthy (more than $100 million in annual income or more than $1 billion in assets) and thinking about expatriation (relinquishing US citizenship or a green card as a long-term resident), the time is now. Even if not super wealthy, the newly proposed Billionaires Income Tax should serve … Continue reading Billionaires Income Tax On the Way & Covered Expats are Hit Hardest of All
Revenue Procedure 2023-34 was released by the IRS on November 9, 2023. It provides full details about the annual inflation adjustments that are important in the world of US tax and impact over 60 tax provisions in the Internal Revenue Code ("Code"), including tax rate schedules and many other tax changes. Tax pro’s have been … Continue reading Tax Planning – “Foreign/International” Annual Inflation Adjustments Coming in 2024
Sometimes I like to bring up issues occurring strictly in the USA and take a peek at how the US tax rules would shake out if foreigners were involved in the transactions. It always makes for a much more complicated analysis. Here is one for today! Let’s look at the juicy story of Justice Clarence … Continue reading The New York Times, USSCt Justice Clarence Thomas, Juicy Gifts & the Tax Lessons!
Part I of my blog post set out the background and discussed the debate over Internal Revenue Code Section 965 “transition tax” or “mandatory repatriation tax” enacted in 2017. The Supreme Court recently decided to review the 9th Circuit case of Moore v. United States bringing this controversial tax back into the spotlight. The Court … Continue reading Should You File a Protective Refund Claim for the Transition Tax While Waiting for the US Supreme Court? Moore Might Mean More!
In recent years, one of the most hotly debated tax issues in the United States has been the imposition by Internal Revenue Code Section 965 of the “transition tax” or “mandatory repatriation tax”, a provision of the Tax Cuts and Jobs Act (TCJA) enacted in 2017. The Supreme Court's recent decision to review the 9th … Continue reading Moore Might Mean More! US Supreme Court Review of Moore & Section 965 Transition Tax
Unsurprisingly, many taxpayers are confused about the tax results of expatriation. One of the most common questions is whether, after having expatriated, but before receiving the CLN, the individual is liable for US tax on his worldwide income. This question likely stems from the Department of State (DOS) policy that while issuance of the CLN … Continue reading Do I Have Worldwide US Tax Liability While Waiting for the Certificate of Loss of Nationality (CLN)?
My earlier blog post covered some US tax issues faced by the individual granted options on foreign company stock by his non-US employer. When it comes to foreign information return reporting, the grant of options to an employee on foreign stock can get confusing. Is an option granted to an employee with respect to foreign … Continue reading FATCA Reporting of Compensatory Foreign Stock Option on Form 8938
Understanding the US gift tax is important for both US and non-US persons. It comes as a big surprise to many people that US gift tax issues can arise in many unanticipated ways, such as sending money to an adult child attending college; making loans interest-free to family members or giving them loans with below-market interest rates. Even non-US persons can … Continue reading Foreign Persons Making Gifts to the US – Cash / Wire Transfers / Checks?
The title of this post could also be “What a Difference a Day Makes”. Most of my readers are quite familiar with the expatriation regime, as I have written many blog posts on this topic. Before delving into the question of the date to use when working through Form 8854, let’s have a quick review … Continue reading Expatriation, Form 8854 & Fair Market Valuation of Assets – Which Date is Used?
Virginia - US TAX TALK 