By now most of my readers will have some familiarity with Internal Revenue Code Section 965, and the “deemed repatriation” or “transition tax” introduced by the Tax Cuts and Jobs Act (“TCJA”) in 2017. My earlier blog post provided significant detail about this new tax law provision which is intended to move the US international tax … Continue reading Section 965 Transition Tax – Enforcement & Audits Begin Next Month
The Internal Revenue Service (IRS) just recently released the 2020 draft Form 1040. In your face right on page one, on a separately colored block: “At any time during 2020, did you receive, sell, send, exchange or otherwise acquire any financial interest in any virtual currency?” This question first appeared for the 2019 tax return, but … Continue reading 2020 Tax Returns & Latest Crypto Developments – In the Crosshairs
I recently spoke on the US tax issues faced by the holder of the green card. To be or not to be such a holder? The podcasts (links below) may help you decide. The podcasts were made with John Richardson, a US and Canadian attorney. John, who is based in Canada, has seen his fair … Continue reading Getting a Green Card – Is it Really Worth It?
Last week's blog post discussed the home office tax deduction and burst the bubble for many who were working at home for months under COVID-19 restrictions. Unfortunately, as discussed in that earlier post, this tax break cannot be used by an individual who is an “employee” as opposed to "self-employed". This restriction is a result … Continue reading COVID-19: Is Employer Provided Assistance due to the Pandemic Taxable Income? What if the Employer is “Foreign”?
In the face of the corona virus, just about everyone I know has been working from home for quite some time. Home can be Stateside or overseas. Many are now asking if they are entitled to take a tax deduction for their “home office”. Here’s everything you need to know. The home office tax break … Continue reading COVID-19: Can I Take a Home Office Deduction?
Recently, I am seeing more and more married couples of dual nationality (with one US individual partner) struggling with the US tax issues wrought by such a "mixed marriage". Some are same sex couples married under the laws of a foreign (non-US) jurisdiction. Believe it or not, marriages taking place in a foreign country (whether … Continue reading Warning: Marriage to a ‘Foreigner’ May Be Hazardous to Your Tax Health
Before delving into the nitty gritty, let me start with a disclaimer. I am not an immigration specialist and this post does not address, other than in a very general manner, immigration issues associated with surrendering a green card at the border. Today’s blog post examines the US tax issues that surround relinquishing the green … Continue reading Surrendering a Green Card at the Border – COVID-19, Stuck Abroad, “Forced” to Surrender Green Card?
In Rev. Proc. 2020-20, the Internal Revenue Service (IRS) provided relief to foreign citizens who were caught out by travel disruptions occasioned by the corona virus, and as a result, remained in the United States for too many days thereby causing them to be subject to US income tax. Under the Revenue Procedure, the IRS will … Continue reading COVID-19 Relief: IRS Helps Foreigners Having Prolonged Presence in the US
Americans working abroad may be eligible to exclude certain foreign earned income (wages, compensation for services) from US taxable income under the rules governing the Foreign Earned Income Exclusion (FEIE). In addition they may be able to exclude certain amounts paid for foreign housing using the Foreign Housing Exclusion (FHE). Both of these benefits are … Continue reading Section 911 FEIE: IRS COVID-19 Relief in Meeting the Bona Fide Residence or Physical Presence Test
As set out in detail in my earlier blog post, the CARES Act amended Internal Revenue Code section 172(b)(1) to provide for a carryback of any net operating loss (NOL) arising in a tax year beginning after December 31, 2017, and before January 1, 2021, to each of the five tax years preceding the tax … Continue reading IRS Provides CARES Act Guidance for Taxpayers with NOLs