JUST ANNOUNCED! Foreign Related Tax Inflation Adjustments for Tax Year 2019

The Internal Revenue Service today announced the tax year 2019 annual inflation adjustments for more than 60 tax provisions, including the tax rate schedules and other tax changes. Revenue Procedure 2018-57 provides details about these annual adjustments. The tax year 2019 adjustments generally are used on tax returns filed in 2020. For those of you … Continue reading JUST ANNOUNCED! Foreign Related Tax Inflation Adjustments for Tax Year 2019 →

Before You Think of Becoming an “American Abroad”, Read This….

I was recently asked about the tax problems faced by Americans who move overseas. Unfortunately, there are many US tax difficulties faced by Americans abroad. In order to make some sense of this vast topic, let's put the major problems into several basic categories. Once aware of the problems lurking out there, you can get … Continue reading Before You Think of Becoming an “American Abroad”, Read This…. →

USA: One Country, Two Citizenships

One Country, Two Citizenships: John Richardson Interviews Virginia La Torre Jeker. Most people don’t know that the US has two kinds of citizenship – “Immigration” citizenship and “Tax” citizenship. Tax citizenship, the monkey on your back, is hard to shake off! Watch the interview, here. All the US tax information you need, every week … Continue reading USA: One Country, Two Citizenships →

All the Fun Rules — US Estate Tax for Nonresident Alien Individuals

Very few US Estate tax returns are actually filed by the estates of nonresident alien individuals. Statistics indicate that the amount of Estate Tax earned by the US Government on such returns is quite small. The cost of structuring to avoid the tax is probably of far greater magnitude than what is collected by the US … Continue reading All the Fun Rules — US Estate Tax for Nonresident Alien Individuals →

MORE Real Life Examples: US Tax Traps of International Community Property

Part I of my blog post explained the basics of community property and how US tax laws can override certain community property principles when a US/NRA married couple is involved. This was followed by a blog post posing a smattering of real-life examples that demonstrated how community property laws can impact the US tax situation … Continue reading MORE Real Life Examples: US Tax Traps of International Community Property →

Real Life Examples: A US Tax Mess, International Community Property

Attention all mixed nationality couples, with one spouse having US citizenship or US resident status while the other is a nonresident alien (NRA)! Your tax advisor should be looking at all possible issues surrounding your fact pattern. If you live in a foreign jurisdiction or US state (there are 9 of them) with a community … Continue reading Real Life Examples: A US Tax Mess, International Community Property →

US Tax Perils of International Community Property

US tax liabilities and requirements to file US tax and information returns are impacted by community property laws that exist in many foreign countries across the globe. Today’s blog post will examine some of these issues and set the stage for upcoming posts dealing with community property in the international context and how it affects … Continue reading US Tax Perils of International Community Property →

Form 5472 – Everything You Need To Know (Part I)

This tax filing season brought a wave of questions about Form 5472. Interest in this complex form was renewed because of recent Treasury Regulations requiring that it be filed by single-member US LLC’s that are foreign owned. Prior to the issuance of these regulations, a single member foreign-owned US LLC was treated as a tax … Continue reading Form 5472 – Everything You Need To Know (Part I) →

Form 5472 – Everything You Need To Know (Part II)

Last week’s 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 of … Continue reading Form 5472 – Everything You Need To Know (Part II) →