Just in time for Christmas, we have two big gifts. Both relate to Malta Pension Plan schemes. If you are too busy to read the post because of the Christmas rush, in a nutshell, they've just been knocked out and the Internal Revenue Service (IRS) is hot on the trail for taxpayers who used them! … Continue reading Malta Pension Plan – IRS Knocks It Out.. and Yes, “I Told You So…..”
Given today’s global economy it comes as no surprise that US taxpayers and the Internal Revenue Service (IRS) must increasingly consider the interactions between US and foreign laws when determining the US tax consequences of a particular transaction. In today’s world, it is no longer possible for practitioners to ignore the possible implications of another … Continue reading HELP! What to do When Foreign Law Impacts the US Tax Analysis of My Case?
Section 121 of the US Internal Revenue Code allows for the exclusion of up to $250,000 ($500,000 for a married couple filing jointly) in gains arising from the sale of a "principal residence." The exclusion applies whether the residence is located Stateside or overseas. The tax law has very specific rules. Aside from the fact that … Continue reading Americans Abroad: Sale of “Principal Residence”, Gain Exclusion, Unforeseen Circumstances & COVID-19
Last week's blog post looked at one way that a non-US citizen can become subject to US income tax on his or her worldwide income - simply by getting a US green card. Today's post looks at the other way one can fall into the US tax trap. “Substantial Presence” in the US An individual … Continue reading Caught in the US Tax Trap: PART II How Does a Non-US citizen Become a US “Resident” – Taxed on WORLDWIDE Income?
US “residents” are subject to tax on income derived from all sources. That means they are subject to tax on their worldwide income regardless of the source of that income. So, for example, dividends earned from a French company are taxable, as is gain on the sale of rental property located in Hong Kong; prize money won … Continue reading Caught in the US Tax Trap: Part I How Does a Non-US citizen Become a US “Resident” – Taxed on WORLDWIDE Income?
Despite the Internal Revenue Service (IRS) recent announcement, it seems to me that the answer is still “Well, it depends!” Here’s my take on the what the IRS said, which to be honest, was just a bit more clear than mud. Taxpayers and tax pros should always look first to whether the FAQ is published … Continue reading IRS Made a Big Announcement – So, Can a Taxpayer Now Rely on IRS FAQ’s?
The House Ways and Means Committee tax proposal unveiled last month has two provisions to shutter lucrative crypto tax loopholes. These are the subject of today’s blog post: the “wash sale” rules and the “constructive sale” rules, both contained in the Internal Revenue Code at Sections 1091 and 1259, respectively. First let’s discuss the so-called … Continue reading Crypto – Harvest Your Tax Losses / Use Offsetting Positions While You Can – Deadline 12/31
The House Ways and Means Committee recently released its proposal (HWM Proposal) to fund the US$3.5 trillion "Build Back Better Act" reconciliation spending package. Not unexpectedly, the proposal takes aim at high income earners. Here’s a few pointers that are important for many of my readers, especially those with US trusts or those looking at … Continue reading Coming Soon! Higher Income and Capital Gains Taxes & More – Beware Trusts, Expatriation Planning
Today' lesson - Choose your US tax advisor very carefully. If he or she lacks the US international/foreign tax experience you may need, reliance on the tax advice may not be considered "reasonable," leading to plenty of penalties. Let's explore! Various civil tax penalties can be assessed when a taxpayer fails to pay the correct … Continue reading Escaping Tax Penalties – “Reasonable Cause” & Reliance on Professional Advice
An IRS online account is a safe and easy way for individual taxpayers to view specific details about their federal tax account. The American Abroad REALLY Needs an Online Tax Account How the US taxpayer living overseas would appreciate having such an online account! Time zone differences, long distance telephone charges when trying to reach … Continue reading International Taxpayers Need – But Can’t Have an IRS Online Account