Marrying A Non-U.S. Citizen? Your S Corp May Be At Risk

U.S. citizens entering marriages with nonresident aliens face a range of tax complexities that extend well beyond routine compliance. In my earlier Forbes article, “A Complicated U.S. Tax Life: Foreign Spouses and Community Property”, I examined how foreign community property regimes, which are prevalent in civil law jurisdictions (e.g., many countries in continental Europe, as … Continue reading Marrying A Non-U.S. Citizen? Your S Corp May Be At Risk →

Home Sale, Forced To Sell Abroad? U.S. Tax Rules In Uncertain Times

Heightened geopolitical tensions across parts of the Middle East are prompting some expatriates to reconsider their long-term plans. For some, this may mean a rapid relocation. Hand in hand with that decision often comes another: whether to sell a residence. As broader economic uncertainty continues to unfold, including market instability, these decisions are increasingly being … Continue reading Home Sale, Forced To Sell Abroad? U.S. Tax Rules In Uncertain Times →

Crypto’s FATCA: Can CARF Close Tax Loopholes If IRS Can’t Keep Up?

The taxman is racing to catch up with crypto’s explosive growth which had 741 million users worldwide just last year. Global crypto reporting has arrived, yet U.S. technology and enforcement capacity continue to lag. Recent reporting by the International Consortium of Investigative Journalists (ICIJ), gives sobering information about the decrease in the number of federal … Continue reading Crypto’s FATCA: Can CARF Close Tax Loopholes If IRS Can’t Keep Up? →

Kwong Case: IRS May Owe You Money, Cut Penalties

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 →

BREAKING! Ex-U.S. Crypto Mogul Indicted: The High Cost of Botched Expatriation

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 →

IRS Under Bisignano: Is More Aggressive Offshore Enforcement Coming?

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? →

IRS Drops Form 708: 40% Tax, Gifts & Bequests, “Covered Expatriates”

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” →

Exclusive Citizenship Act: Unintended Consequences Continue To Emerge

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 →

Moreno’s Fast-Track Citizenship Bill: Tax & Social Security Bombs, Diplomatic Chaos & More

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 →

Offshore Crypto: IRS Steps Closer To Automatic Reporting Under OECD CARF

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 →