Residence-Based Taxation: Social Security, Pensions And 30% Withholding

The endorsement of an elective residence-based taxation model by former IRS Commissioner Charles Rettig and former IRS Commissioner Counselor Tom Cullinan, covered in my earlier Forbes article, has sparked important discussions about fairness for Americans abroad. Their piece highlights the burdens of America’s citizenship-based tax system and calls for a shift to treat expats more … Continue reading Residence-Based Taxation: Social Security, Pensions And 30% Withholding →

What Every American Overseas (or Dreaming of Living Overseas) Must Know 2025

Thinking of moving overseas, or already living abroad as an American? One thing you can’t escape is U.S. taxes. In this video, I sit down with Jahtna Hernandez to discuss the unique challenges Americans face under a citizenship-based tax system, and the key rules every expat, retiree, or digital nomad needs to know in 2025. … Continue reading What Every American Overseas (or Dreaming of Living Overseas) Must Know 2025 →

U.S. Tax Rules: IRAs After Giving Up Citizenship Or Green Card

Imagine over the years that you’ve built a nest egg in a U.S. Individual Retirement Account, Roth IRA, or Simplified Employee Pension IRA. This is a common scenario for many U.S. citizens and green card holders while working in the United States. In a scenario that is becoming increasingly more common, imagine that after years … Continue reading U.S. Tax Rules: IRAs After Giving Up Citizenship Or Green Card →

Taxation Of Stock Options For Foreign Nationals Working In The U.S.

Many foreign persons are employed in America and are given stock options as an incentive by the companies for which they work. When a foreign national works in the U.S. and is granted stock options, the taxation of these options can become complex, especially if the individual later leaves the U.S. and becomes a nonresident alien … Continue reading Taxation Of Stock Options For Foreign Nationals Working In The U.S. →

PODCAST! Crash Course Info! Renouncing US Citizenship / Relinquishing Green Card – Beware The Exit Tax and More

A very informative podcast - I would say it's a crash course on the US #expatriation regime including the recently issued final IRS regs on the Sec. 2801 transfer tax, lots of tax tips including gifting issues to get below USD 2 million threshold, what NOT TO DO if CBP wants you to sign I-407 … Continue reading PODCAST! Crash Course Info! Renouncing US Citizenship / Relinquishing Green Card – Beware The Exit Tax and More →

Malta Pension Plan – IRS Knocks It Out.. and Yes, “I Told You So…..”

Just in time for Christmas, we have two big gifts. Both relate to Malta Pension Plan schemes. If you are too busy to read the post because of the Christmas rush, in a nutshell, they've just been knocked out and the Internal Revenue Service (IRS) is hot on the trail for taxpayers who used them! … Continue reading Malta Pension Plan – IRS Knocks It Out.. and Yes, “I Told You So…..” →

Renouncing One’s US Citizenship: More Audits, Virtual Currency, CLN & Travel

COVID-19 restrictions have severely limited services at US embassies and consulates around the world. As a result, renouncing one’s US citizenship has become very difficult, and in many cases, just about impossible at the current time. This gives individuals more time to make sure they have properly planned for expatriation. It's a big step. I … Continue reading Renouncing One’s US Citizenship: More Audits, Virtual Currency, CLN & Travel →

Foreign Pension Plans / Retirement Trusts – Is IRS Seeing the Light?

The Internal Revenue Service (IRS) - starting to see some light with respect to "foreign" pension plans? The US tax issues surrounding foreign pensions and retirement schemes is extremely complex and has vexed tax professionals and US persons abroad for many years. (Read my earlier blog post here). Due to the diversity of such plans, … Continue reading Foreign Pension Plans / Retirement Trusts – Is IRS Seeing the Light? →

Oh No! I Have a “Foreign” Pension or Employee Savings Plan and Uncle Sam is Killing Me (Part I)

“Foreign” pension or similar plans are a very common feature in the lives of US expats residing and working abroad. As used here, the word “pension” is only a general term. While pensions in the United States often refer to defined benefit retirement plans, my use in today’s blog post refers to a pension as … Continue reading Oh No! I Have a “Foreign” Pension or Employee Savings Plan and Uncle Sam is Killing Me (Part I) →

Expatriation: Deferring Payment of the Exit Tax

I recently blogged about the debate between Prof. Edward Zelinsky and John Richardson as it pertained to the Exit Tax imposed on so-called "covered expatriates". This was in the broader context of the US income taxation model which is based on one's "citizenship" rather than one's residence. The thrust of my earlier blog post concerned … Continue reading Expatriation: Deferring Payment of the Exit Tax →