National Taxpayer Advocate – Pushes for Positive Changes for Americans Abroad

The law requires the National Taxpayer Advocate (NTA) to submit two annual reports to the House Committee on Ways and Means and the Senate Committee on Finance, without any prior review or comment from the Internal Revenue Service. The NTA Report for FY 2025 was just issued and includes various NTA advocacy objectives. Two of the … Continue reading National Taxpayer Advocate – Pushes for Positive Changes for Americans Abroad →

How Long Does The IRS Have To Catch Your U.S. Tax Mistake? 6 Scenarios

My article copied below, first appeared on Forbes June 11, 2024 – link here. It explains the important rules to know when IRS comes calling to review prior filed tax returns and assess additional taxes. How long can the IRS come after a taxpayer for tax errors or worse? The tax statute of limitations can … Continue reading How Long Does The IRS Have To Catch Your U.S. Tax Mistake? 6 Scenarios →

BREAKING! Expatriation No Cure: Bitcoin Jesus Indicted & Arrested on Tax Fraud

Roger Ver, an early bitcoin investor (from approximately 2011) also known as “Bitcoin Jesus,” was just arrested in Spain based on US criminal charges. According to the indictment filed February 15, 2024 but recently unsealed, Ver has been charged with mail fraud, tax evasion, and filing false tax returns. Ver was a former US citizen who … Continue reading BREAKING! Expatriation No Cure: Bitcoin Jesus Indicted & Arrested on Tax Fraud →

Death Of The American Abroad: Untangling U.S. Tax Across Borders

Many of my readers know I am now a contributor writing on Forbes. My coverage area is US international tax law for overseas Americans and foreigners. My article is copied below. It first appeared on Forbes April 22, 2024 here. In our global society, more and more Americans are living and working overseas. This inevitably … Continue reading Death Of The American Abroad: Untangling U.S. Tax Across Borders →

Accidental Americans Learning They Are Citizens Face A Tax Dilemma

As some of my readers know, I am now a contributor writing on Forbes. My coverage area is US international tax law for overseas Americans and foreigners. My article is copied below. It first appeared on Forbes April 9, here. Don't miss out on my informative and easy-to-understand US tax content - Follow me on … Continue reading Accidental Americans Learning They Are Citizens Face A Tax Dilemma →

IRS E-Filing Plan: No Solution for the Overseas American

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 →

Post-Bittner, IRS Gets Tougher on “Nonwillful” FBAR Penalties

As predicted, the fallout from the United States Supreme Court decision in Bittner v. United States, means a tougher stance by the Internal Revenue Service (IRS) when it comes to reducing so-called “FBAR” penalties for “nonwillful” violations. In a nutshell, the Bittner court held that the Bank Secrecy Act (BSA) $10,000 maximum penalty for the … Continue reading Post-Bittner, IRS Gets Tougher on “Nonwillful” FBAR Penalties →

US Tax Issues Abound: A Global Look at Protecting Vulnerable Persons from Financial Fraud (The Case of the Wicked Stepdaughter)

On Wednesday I presented a webinar for the Financial Planning Association’s July International & Cross-Border Planning Knowledge Circle. My webinar highlighted numerous US tax issues when safeguarding the finances of the elderly (or other vulnerable individuals), whether Stateside or overseas. You can listen to the entire webinar here. The Case of the Wicked Stepdaughter A … Continue reading US Tax Issues Abound: A Global Look at Protecting Vulnerable Persons from Financial Fraud (The Case of the Wicked Stepdaughter) →

FATCA Statute of Limitations: IRS’ 2018 Assessment Grabs Tax & Penalties Back to 2003

In Fairbank v. Commissioner, T.C. Memo. 2023-19, Dkt. No. 13400-18 (February 23, 2023) the Internal Revenue Service (IRS) issued a notice of deficiency in April 2018 for taxable years 2003, 2004, 2005, 2006, 2007, 2008, 2009, and 2011. The taxpayers argued the IRS could not go back to these prior years, challenging the assessments on … Continue reading FATCA Statute of Limitations: IRS’ 2018 Assessment Grabs Tax & Penalties Back to 2003 →

Tax Statutes of Limitation – Run Fast, IRS is Right Behind You

With tax season in full swing, now is a good time to review the various civil statutes of limitations (SOL) rules that apply to US tax matters. Perfect timing to review because we also have a Tax Court case from last month showing how harsh the consequences of the SOL can be if a taxpayer … Continue reading Tax Statutes of Limitation – Run Fast, IRS is Right Behind You →