Leaked Memo Includes Major Tax Reform And Impacts U.S. Persons Abroad

A recently leaked memorandum discussed by JD Supra, has revealed potential tax reform under discussion in the U.S. House of Representatives. These share some key elements with President Donald Trump’s tax reform proposals, reflecting a coordinated effort to implement significant change. The leaked information contains changes that could reshape the tax obligations of U.S. persons … Continue reading Leaked Memo Includes Major Tax Reform And Impacts U.S. Persons Abroad →

Owning Real Estate Property Overseas: 9 Key U.S. Tax Issues

Purchasing or owning real estate property overseas can be an exciting investment opportunity, but for U.S. persons, it comes with significant tax and reporting obligations. Foreign persons becoming U.S. tax residents (e.g., obtaining a green card) may already own overseas properties and should be aware of the U.S. tax issues they will face at the … Continue reading Owning Real Estate Property Overseas: 9 Key U.S. Tax Issues →

Cross-Border Tax Collection: IRS Tools To Seize Foreign Assets

The process for IRS to seize foreign assets to satisfy tax debts is not simple. IRS use of the so-called John Doe summons is often a first step to identify possible tax evasion with offshore assets, as noted in the recent case involving Trident Trust. After resolution of the tax matter, the IRS is faced … Continue reading Cross-Border Tax Collection: IRS Tools To Seize Foreign Assets →

Offshore Tax Evasion: U.S. Clients Of Trident Trust Target Of IRS John Doe Summons

The Department of Justice and the Internal Revenue Service have recently reaffirmed their strong commitment to pursuing offshore tax evasion through the use of powerful investigative tools. One such tool is the IRS John Doe Summons. On Dec. 23, 2024, the United States District Court for the Southern District of New York granted the IRS authority … Continue reading Offshore Tax Evasion: U.S. Clients Of Trident Trust Target Of IRS John Doe Summons →

Cross-Border Transactions: Foreign Laws And U.S. Tax In A Borderless World

In today’s interconnected world, borders blur while regulations multiply. Families span continents, careers pivot across countries, and even currencies like Bitcoin redefine value. Meanwhile, the U.S. tax system casts an ever-wider net, taxing its citizens on worldwide income regardless of where they reside. Through measures like the Foreign Account Tax Compliance Act, the U.S. government … Continue reading Cross-Border Transactions: Foreign Laws And U.S. Tax In A Borderless World →

Bitcoin Jesus Challenges Constitutionality Of Expatriation “Exit Tax”

Roger Ver, an early Bitcoin investor renowned as “Bitcoin Jesus” for his evangelism of cryptocurrency since 2011, now finds himself in a legal maelstrom. Ver, a controversial figure in the blockchain world, was arrested in April 2024 in Spain on U.S. criminal charges stemming from allegations of mail fraud, tax evasion, and filing false tax … Continue reading Bitcoin Jesus Challenges Constitutionality Of Expatriation “Exit Tax” →

Americans Living Abroad: Foreign Housing Tax Break, Explained

Overseas Americans are entitled to certain tax breaks assuming various qualifications are met. One of the significant tax breaks is the ability to exclude from taxable income certain amounts provided by an employer for foreign housing. Housing costs are “personal” in nature and the tax laws do not provide exclusions or deductions for personal expenditures. A … Continue reading Americans Living Abroad: Foreign Housing Tax Break, Explained →

IRS Just Launched Pass-Through Compliance Unit: Heightened Focus on Trusts Including Foreign Foundations

The IRS has established a new pass-through compliance unit within its Large Business and International division, as announced on October 22, 2024. This unit aims to tackle “complex financial arrangements”, targeting high-net-worth individuals and entities that use partnerships, S-corporations, and trusts to reduce their tax burdens. Funded by the Inflation Reduction Act, the initiative seeks … Continue reading IRS Just Launched Pass-Through Compliance Unit: Heightened Focus on Trusts Including Foreign Foundations →

IRS Tax Records, Foreign Assets: When (And What) To Keep Or Toss

Many people face the dilemma of what to do with old tax returns and supporting paperwork, often wondering when it’s safe to discard them. However, determining the right time can be tricky, especially for taxpayers with foreign assets. Those with overseas financial interests must pay particular attention for several reasons, including expanded statutes of limitation … Continue reading IRS Tax Records, Foreign Assets: When (And What) To Keep Or Toss →

IRS Tax Penalty Forgiveness: Challenge Of Proving “Reasonable Cause”

Tax penalties can be a harsh reality for many taxpayers, especially those dealing with complex international tax obligations. The IRS imposes penalties to encourage compliance and deter negligence. This article provides a general overview of commonly encountered tax penalties, and then delves into the often-misunderstood penalty relief, "reasonable cause.” Overview Of Tax Penalties Tax penalties … Continue reading IRS Tax Penalty Forgiveness: Challenge Of Proving “Reasonable Cause” →