Dangerous Liaisons: Foreign Assets and the US Nominee

We’ve known for some time that the Internal Revenue Service (IRS) has been mining heaps of data provided to it by financial institutions that were the subject of non-prosecution agreements, as well as examining treasure troves of financial information from various leaks (think “Panama Papers”) looking not only for tax dollars, interest and penalties but … Continue reading Dangerous Liaisons: Foreign Assets and the US Nominee

Alimony – No Need for Tax Confusion Even if Paying a Nonresident Alien Individual

My readers know that broad US tax reform was enacted in December 2017 pursuant to the Tax Cuts and Jobs Act (“TCJA”).  As of January 1, 2019, the TCJA’s new tax rules impacted any US spouse who was either paying or receiving alimony under a divorce or separation agreement executed after December 31, 2018. Under … Continue reading Alimony – No Need for Tax Confusion Even if Paying a Nonresident Alien Individual

OOOOPS! I Received a Gift from a Foreign Corporation (or Foreign Partnership)

Here in the Middle East where I have been practicing for almost two decades, I have seen that it is very common for families to create offshore structures in various countries (outside the USA) to hold a large portion of the family wealth.  The underlying reasons for maintaining these structures outside of the family’s home … Continue reading OOOOPS! I Received a Gift from a Foreign Corporation (or Foreign Partnership)

D is for “Domicile”, Don’t Disregard!

Several of my recent blog posts set the stage showcasing the serious US tax issues that can arise for a married couple when only one  is a US person and they are impacted by application of a foreign country’s community property laws.  You can read these blog posts here, here and here. For example, if funding … Continue reading D is for “Domicile”, Don’t Disregard!

Ground-Breaking Development: IRS “Amnesty” Relief for Certain Expatriates!

The Internal Revenue Service (IRS) announced today new Relief Procedures for Certain Former Citizens that will enable certain individuals who relinquished 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, or any penalties or interest!  It sounds … Continue reading Ground-Breaking Development: IRS “Amnesty” Relief for Certain Expatriates!

Life Gets Complicated When a Foreign Country’s Laws Impact US Tax

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

US Immigrant’s Residency Starting Date – The Devil’s Details – Too Many Days in the USA?

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?

Getting an ITIN When Overseas: Help!

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!

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