Virginia La Torre Jeker, J.D. — US tax matters affecting international clients
Taxpayers have often struggled with shifting tax filing deadlines and complex IRS penalty calculations. But if some of those filing deadlines were legally postponed by an act of Congress, certain penalties and refund interest may have been incorrectly calculated by the IRS, entitling impacted taxpayers to relief. A recent federal court case may offer some … Continue reading Kwong Case: IRS May Owe You Money, Cut Penalties
In a stark reminder of the complexities and pitfalls of renouncing U.S. citizenship, a federal grand jury in the Western District of Texas recently indicted Justin Ryan Schmidt on multiple tax-related charges. Mr. Schmidt, a Cayman Islands national, is a former U.S. citizen and cryptocurrency hedge fund manager. He became a naturalized British citizen in … Continue reading BREAKING! Ex-U.S. Crypto Mogul Indicted: The High Cost of Botched Expatriation
Right before the U.S. tax filing season officially opened on January 26, the Internal Revenue Service announced significant leadership changes that have drawn cautious scrutiny from tax professionals. Practitioners with the high-net-worth clients and those who assist Americans living abroad are paying close attention. While IRS leadership transitions regularly occur, the timing and substance of … Continue reading IRS Under Bisignano: Is More Aggressive Offshore Enforcement Coming?
The Internal Revenue Service has released the final version of Form 708, titled “United States Return of Tax for Gifts and Bequests Received from Covered Expatriates,” (revision dated December 2025) along with detailed draft instructions (revision dated December 2025). As of today’s publication, the accompanying instructions remain in draft form available only as a draft … Continue reading IRS Drops Form 708: 40% Tax, Gifts & Bequests, “Covered Expatriates”
I have previously written how changes to U.S. citizenship and expatriation rules often produce consequences far beyond what legislators appear to anticipate. Whether in the tax arena or in the administration of federal benefits, citizenship status functions as a foundational legal concept, not a standalone policy. Senator Moreno’s proposed “Exclusive Citizenship Act” underscores this point. … Continue reading Exclusive Citizenship Act: Unintended Consequences Continue To Emerge
One email from a tribal member sparked today’s article. A Native American reader of my recent Forbes piece on Senator Bernie Moreno’s Exclusive Citizenship Act of 2025 wrote in with a simple, powerful question: “How would this affect us?” In fewer than 10 words, that message prompted me to dig much deeper. What follows is … Continue reading Moreno’s Fast-Track Citizenship Bill: Tax & Social Security Bombs, Diplomatic Chaos & More
The United States along with over 70 other countries has adhered to the Joint Statement on the OECD’s Crypto-Asset Reporting Framework, “CARF”. CARF is the digital-asset counterpart to the Common Reporting Standard “CRS” that has exchanged bank and securities account data among signatory countries (now well over 100 countries). The United States has formally indicated … Continue reading Offshore Crypto: IRS Steps Closer To Automatic Reporting Under OECD CARF
Each year, thousands of children are born overseas to one U.S. citizen parent and one non-U.S. parent. Under U.S. immigration law, many of these children are U.S. citizens from birth, provided the American parent satisfies a relatively simple test: at least five years of physical presence in the United States, with two of those years … Continue reading Unregistered U.S. Citizenship: Hidden Risks For American Born Abroad
Many children born overseas to a U.S. parent are U.S. citizens from birth. This is so even if the parents never registered the birth at a U.S. Consulate or Embassy, or applied for a U.S. passport for the child. Some parents view this as a way to keep the child outside the U.S. tax system, … Continue reading Born Abroad, American by Law: Should You Register Your Child?
When love crosses borders, tax complexity often follows. I know this from first-hand experience having married a Swiss national almost 4 decades ago. When U.S. citizens marry foreign nationals who are not U.S. tax residents a host of U.S. tax rules can upend marital bliss by causing tax compliance complexities that are often difficult to … Continue reading A Complicated U.S. Tax Life: Foreign Spouses And Community Property
Virginia - US TAX TALK 