PFICs – The Fairytale Definition That Lives Happily Ever After…

I was hoping that tax reform would have done away with, or at least modified, the troublesome provisions surrounding the PFIC or so-called “Passive Foreign Investment Company”.  This was not to be and it prompted me to review the PFIC rules and count the ways they cause trouble! What is a PFIC? A PFIC is … Continue reading PFICs – The Fairytale Definition That Lives Happily Ever After…

It’s Finally Here: The IRS Bible for Voluntary Disclosures

As many will remember, the Offshore Voluntary Disclosure Program (OVDP) closed on September 28th with the promise that the Internal Revenue Service (IRS) would issue new guidance on voluntary disclosures made after that date.  The guidance just arrived in the form of a 5-page Memorandum by Kristen B. Wielobob, Deputy Commissioner for Services and Enforcement, … Continue reading It’s Finally Here: The IRS Bible for Voluntary Disclosures

Married to A Non-US Spouse? Use of “Resident” Election, Filing FBAR and Form 8938

My blog post containing tax-saving tips for the filing of a US income tax return when one is married to  a non-resident alien spouse is here. It will be helpful to read that post before embarking on this one as it sets out the basics and provides the income tax rates and brackets for the 2018 … Continue reading Married to A Non-US Spouse? Use of “Resident” Election, Filing FBAR and Form 8938

Married to A Non-US Spouse? Tax Saving Tips For the US Income Tax Return

A US citizen or US tax resident (for example, a green card holder) who is married to a non-American when the couple lives abroad should consider certain US tax filing issues and strategies. US Tax Treatment of the Non-US Spouse When the non-US citizen spouse has obtained a green card or is otherwise treated as a … Continue reading Married to A Non-US Spouse? Tax Saving Tips For the US Income Tax Return

Americans Abroad: October 15 Tax Filing Deadline – Not Ready? Don’t Panic

US persons living and working overseas often find it more difficult to meet the deadlines for their tax returns. This is so because they may have foreign financial assets that require a more extensive tax analysis to prepare the return. Just think about the work required to figure out the “transition tax” or “deemed repatriation … Continue reading Americans Abroad: October 15 Tax Filing Deadline – Not Ready? Don’t Panic

Reminder – If You Hate Your Spouse As Much as You Hate Paying Taxes …

My readers know that broad US tax reform was enacted in December under the commonly called Tax Cuts and Jobs Act (“TCJA”).  Today’s post is a reminder of how the new tax rules will impact any US spouse who will be either paying or receiving alimony.   The clock is ticking and action must be taken … Continue reading Reminder – If You Hate Your Spouse As Much as You Hate Paying Taxes …

Americans Abroad: Sept 18, LONDON – Push to End Citizenship-Based Taxation

A lively discussion is set to drum up support to convince US lawmakers to end America’s increasingly-unpopular “citizenship-based” tax regime. The meeting will take place in London next week. When: Tuesday 18 September 2018 - 17:30 to 19:00 Where: Central London location – to be confirmed upon RSVP (nearest tube: Westminster) Venue: To be provided upon RSVP (nearest … Continue reading Americans Abroad: Sept 18, LONDON – Push to End Citizenship-Based Taxation

Kotholos – New Case Shows IRS Aggression in Asserting FBAR “Willful” Penalty

I have been blogging recently (here and here) about the IRS’ aggressive stance in determining what constitutes a taxpayer’s “willful” failure to file an FBAR and the fact that mounting court cases show the judiciary is buying in to the IRS’ position.  Courts appear to be more easily upholding a finding of “willfulness” when it … Continue reading Kotholos – New Case Shows IRS Aggression in Asserting FBAR “Willful” Penalty

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

Tax Primer: US Expats & Foreigners

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Everything you need to know about US tax is right here at your fingertips!  My primer provides information for overseas Americans and green card holders on US tax obligations including Income Tax, Estate Tax and Gift Tax as well as IRS reporting requirements and State income tax. It also provides detailed information for foreign individuals … Continue reading Tax Primer: US Expats & Foreigners