Cryptocurrency: Dissecting Revenue Ruling 2019-24 Treatment of Chain Splits

In this Tax Notes article published today, February 24, 2020 attorneys Arvind Ravichandran and Maurio Fiore, associates at the law firm Cravath, Swaine & Moore LLP, explain in fascinating detail the ABC’s of cryptocurrency, the workings of the mysterious blockchain technology and carefully dissect the IRS’ recent guidance enunciated in Revenue Ruling 2019-24. The article … Continue reading Cryptocurrency: Dissecting Revenue Ruling 2019-24 Treatment of Chain Splits →

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

Part I of this blog post introduced the topic of the "foreign" pension or employee workplace savings plan, and examined in some detail how these plans are becoming more and more popular in the United Arab Emirates. The plans, however, give US expatriate employees some serious US tax headaches. Today's post focusses on these thorny … Continue reading Oh No! I Have a “Foreign” Pension or Employee Savings Plan and Uncle Sam is Killing Me (Part II) →

Expatriated? But Failed to File Form 8854? IRS Provides a Fix!

2020 looks promising in more ways than one. First, on a professional level I was delighted and proud to be named, for the 4th year running, to Forbes Top 100 Must Follow Tax Twitter Accounts for 2020. Please do encourage your friends and colleagues to follow me on Twitter and to subscribe to my US … Continue reading Expatriated? But Failed to File Form 8854? IRS Provides a Fix! →

Cryptocurrency and Your 2019 Tax Return – Handle With Care

It’s been no secret that cryptocurrency is in the crosshairs of the Internal Revenue Service (IRS). Virtual currency is one of the IRS “campaigns” and criminal investigations related to crypto already started last year. Taxpayers are being sent “educational” letters to remind them and warn them of their tax obligations when it comes to the … Continue reading Cryptocurrency and Your 2019 Tax Return – Handle With Care →

IRS: The Grinch Who Stole Christmas

Christmas was on our doorstep not too long ago and was marked by a time of giving and rejoicing. In the employment context, overseas employers with American staff may have been more inclined to be generous in gift-giving, as many of its US employees were away from their Stateside family over the holiday period. The … Continue reading IRS: The Grinch Who Stole Christmas →

ATTENTION! Married Filing Separately? $5 of Gross Income? Must File US Income Tax Return!

Yes, that did read US$5. Not $50. Not $500……This measly number will heavily impact Americans abroad who are married to non-US spouses. In many instances, the US spouse will file separately and keep the non-US spouse completely out of the US tax picture. This may not always be the best tax strategy but in some … Continue reading ATTENTION! Married Filing Separately? $5 of Gross Income? Must File US Income Tax Return! →

IRS “Relief Procedures for Certain Former Citizens” – Hey! What About Green Card Holders?

In September 2019, the Internal Revenue Service (IRS) announced new Relief Procedures for Certain Former Citizens that will enable certain individuals who relinquished (or are relinquishing) their US citizenship to come into compliance with their US tax and filing obligations. These lucky individuals will not have to pay the back taxes otherwise owed; nor will … Continue reading IRS “Relief Procedures for Certain Former Citizens” – Hey! What About Green Card Holders? →

Dangerous Liaisons: Foreign Assets and the US Nominee

We’ve known for some time that the Internal Revenue Service (IRS) has been mining heaps of data provided to it by financial institutions that were the subject of non-prosecution agreements, as well as examining treasure troves of financial information from various leaks (think “Panama Papers”) looking not only for tax dollars, interest and penalties but … Continue reading Dangerous Liaisons: Foreign Assets and the US Nominee →

President Trump – Expatriating?

Well, if my dream last night has anything to do with reality, the world is in for a big shakeup. In my dream, President Trump came to me for US tax advice on expatriation - that is giving up one's US citizenship (or, green card in the case of long term residents). What a bizarre … Continue reading President Trump – Expatriating? →

US Beneficiary of Foreign Trust: Understanding US Tax Filings

I have written a series of blog posts about foreign (i.e., non-US) trusts and the US tax issues associated with them including the US tax filing and reporting requirements for each of the different players in the foreign trust scenario (creator or "grantor"/"settlor" of the trust), the trustee; and today, the US beneficiary. One of … Continue reading US Beneficiary of Foreign Trust: Understanding US Tax Filings →