US Citizenship And Worldwide Taxation: Justified?

Tune in to the amazing debate between John Richardson and Edward Zelinsky, two renowned tax and citizenship professionals, taking place on Friday May 17.  Not only is it free,  but viewers will receive an unparalleled education about the major issues surrounding US citizenship, its tax consequences for the typical American abroad and Accidental Americans, effects … Continue reading US Citizenship And Worldwide Taxation: Justified?

Head’s Up! IRS Just Revised EIN Application Procedure & Foreign Taxpayers Will Struggle

Effective as of May 13, taxpayers can no longer request an employer identification number (EIN) unless the "responsible party" named on the application has either a Social Security Number (SSN) or Individual Taxpayer Identification Number  (ITIN). Only governmental entities and the military are exempt from this requirement, and may continue to list non-individual entities as … Continue reading Head’s Up! IRS Just Revised EIN Application Procedure & Foreign Taxpayers Will Struggle

The Foreigner and the Taxman: Are You “Married” for US Income Tax Purposes?

Life gets confusing when you’re an American and you’ve married a “foreigner”.  Aside from the cultural and social differences you may encounter, you cannot forget that your US tax situation will now become even more complex.  Many of my tax blog posts explain the thorny side of filing US income tax returns, FBARs and various … Continue reading The Foreigner and the Taxman: Are You “Married” for US Income Tax Purposes?

Head’s Up! Foreign-Owned Single Member US LLC: Increase in Penalties for Form 5472

My earlier blog post covered some basics about Form 5472, including how the Form helps the US Internal Revenue Service (IRS) learn about foreign-owned businesses in the US and when to audit them, the meanings of certain terms such as what is meant by a “reportable transaction” with a “related party”, and the situation requiring filing … Continue reading Head’s Up! Foreign-Owned Single Member US LLC: Increase in Penalties for Form 5472

US Tax Law to American Abroad – “How Do I Hate Thee, Let Me Count the Ways”

Regular readers of my tax blog will not be surprised by the title of this post and the content it hints at delivering. They likely realize by now that the American person abroad is not looked upon favorably by the US tax laws.  The tax laws look at anything “foreign” with a jaundiced eye when … Continue reading US Tax Law to American Abroad – “How Do I Hate Thee, Let Me Count the Ways”

The #FBAR Marriage – A Troublesome Union

I was just recently interviewed on Canadian TV in 3 different sessions covering the US tax complications when a US person and non-US person are married (US income tax, gift tax, estate tax). I am being interviewed by John Richardson, a Canadian and US attorney. John calls this phenomenon the #FBARMarriage. Some marriages don't last -- … Continue reading The #FBAR Marriage – A Troublesome Union

Property Transfers at Divorce and the Foreign (Non-US) Spouse

As if divorce were not a stressful enough time, the complexities of the US tax rules when a non-US spouse is involved just make it all the more unbearable.  Keep in mind, too, that foreign divorces can add further legal complexity to the mix and professional help should always be sought. This is so because when foreign … Continue reading Property Transfers at Divorce and the Foreign (Non-US) Spouse

Mechanics of the Substantial Presence Test and Exemptions: Foreign Teacher, Student, Trainee, Government Employee in the US

Once a non-US individual is classified for income tax purposes as a “resident” he is subject to income tax in the same manner as a US citizen: i.e., taxed on his worldwide income (meaning income from all sources whether from within or outside the US) at a maximum rate of 37 percent (this top rate … Continue reading Mechanics of the Substantial Presence Test and Exemptions: Foreign Teacher, Student, Trainee, Government Employee in the US

Tax Court, IRS Speak with Forked Tongue? Section 6013(g) Election to Treat Foreign Spouse as US “Resident”

I have written a few blog posts on the thorny side of filing US income tax returns, FBARs and various information returns when one is married to  a non-resident alien (NRA) spouse.  It may be helpful to read those posts here and here before embarking on this one as the earlier posts set out some … Continue reading Tax Court, IRS Speak with Forked Tongue? Section 6013(g) Election to Treat Foreign Spouse as US “Resident”

Gifts & Bequests from Former Americans – Beware that Trojan Horse

Former US citizens or long term permanent residents who are giving up (or previously gave up) their US status, have far more than just the "Exit Tax" to worry about. They must also consider the impact the expatriation will have on their US family members and other intended US beneficiaries. I'm still waiting for more … Continue reading Gifts & Bequests from Former Americans – Beware that Trojan Horse