Virginia La Torre Jeker, J.D. — US tax matters affecting international clients
My article copied below, first appeared on Forbes May 20, 2024 – link here. Follow me on Forbes - it's free and your gateway for easy to understand US international tax coverage. I’ve got 40 years of tax experience and am very careful with my blog posts to ensure accurate information is being provided. Just … Continue reading Foreign Spouse? Vexing U.S. Tax Issues For The American Half
I have written earlier on the case of Farhy v. Commissioner. There the Tax Court held that the IRS does not have the authority to assess and collect penalties asserted under Internal Revenue Code Section 6038(b). In the Farhy case, the assessed penalties were imposed for failure to file Form 5471, the IRS form required … Continue reading Another Breaking! Farhy Overruled – A Big Loss for Overseas Americans
Roger Ver, an early bitcoin investor (from approximately 2011) also known as “Bitcoin Jesus,” was just arrested in Spain based on US criminal charges. According to the indictment filed February 15, 2024 but recently unsealed, Ver has been charged with mail fraud, tax evasion, and filing false tax returns. Ver was a former US citizen who … Continue reading BREAKING! Expatriation No Cure: Bitcoin Jesus Indicted & Arrested on Tax Fraud
As some of my readers know, I am now a contributor writing on Forbes. My coverage area is US international tax law for overseas Americans and foreigners. My article is copied below. It first appeared on Forbes April 14, 2024 here. Don't miss out on my informative and easy-to-understand US tax content - Follow me … Continue reading Insights For Foreigners: Navigating The U.S. Tax Maze Before Residency
As some of my readers know, I am now a contributor writing on Forbes. My coverage area is US international tax law for overseas Americans and foreigners. My article is copied below. It first appeared on Forbes April 9, here. Don't miss out on my informative and easy-to-understand US tax content - Follow me on … Continue reading Accidental Americans Learning They Are Citizens Face A Tax Dilemma
Discovered an error in a prior year’s tax return? Everyone is busy preparing US tax returns for 2023. Taxpayers should note that thorough preparation of the current year’s tax return should include a review at least, of the return filed for the prior tax year. (Taxpayers using new return preparers should be wary if … Continue reading To Amend or Not to Amend – That is the Question
I have written before about the new Internal Revenue Service (IRS) Direct File pilot program. "Eligible" taxpayers in 12 states can now file their 2023 US tax returns directly with the IRS (for free). No more need for Turbo Tax or a tax return preparer! According to the IRS, the Direct File pilot is easy … Continue reading IRS Direct File Pilot Program: Up & Running, but Not for Everyone!
How difficult is it for a taxpayer to establish “reasonable cause” such that penalties for various tax mishaps can be forgiven or abated? It’s very difficult. The recent case of Wayne Lee v. United States, No. 22-10793 (11th Cir. 10/24/23) underscores the point and reminds taxpayers to get reliable tax advisors and return preparers. Going … Continue reading Taxpayer Denied “Reasonable Cause” When Preparer Fails to e-file Returns
As will be recalled from the previous blog posting discussing the basics of so-called "Controlled Foreign Corporations" (CFC), a United States shareholder of a CFC can possibly be treated as having received “dividend” income at various times. These are when the US shareholder has (i) current income inclusions from the CFC under the anti-deferral regime (Subpart F … Continue reading “Qualified Dividend Income”: How do the Rules Apply to “Controlled Foreign Corporations?” (Part II)
In IRS Notice 2024-11, the Internal Revenue Service (IRS) updated the list of treaties that can provide a foreign corporation with the special status of being a “qualified foreign corporation” (QFC). The list was updated to include the treaty with Chile, which entered into force on December 19, 2023, and to remove the treaty with … Continue reading Dividends Paid by Foreign Corporations – Are they “Qualified” & Eligible for Capital Gain Rates?
Virginia - US TAX TALK 