Category: Personal Income Tax

Moore Might Mean More! US Supreme Court Review of Moore & Section 965 Transition Tax 

In recent years, one of the most hotly debated tax issues in the United States has been the imposition by Internal Revenue Code Section 965 of the “transition tax” or “mandatory repatriation tax”, a provision of the Tax Cuts and Jobs Act (TCJA) enacted in 2017. The Supreme Court's recent decision to review the 9th … Continue reading Moore Might Mean More! US Supreme Court Review of Moore & Section 965 Transition Tax  →

Do I Have Worldwide US Tax Liability While Waiting for the Certificate of Loss of Nationality (CLN)?

Unsurprisingly, many taxpayers are confused about the tax results of expatriation. One of the most common questions is whether, after having expatriated, but before receiving the CLN, the individual is liable for US tax on his worldwide income.  This question likely stems from the Department of State (DOS) policy that while issuance of the CLN … Continue reading Do I Have Worldwide US Tax Liability While Waiting for the Certificate of Loss of Nationality (CLN)? →

Malta Retirement Plans – The Jig is Really Up!

Things are looking worse and worse for Americans who invested in Malta personal retirement plans. Not only has the Internal Revenue Service (IRS) listed them twice on its Dirty Dozen tax scams list, it has now proposed rules that will require taxpayers and material advisers to specially put the IRS on notice about their use.  … Continue reading Malta Retirement Plans – The Jig is Really Up! →

IRS Updates its Audit “Campaign” Targets – Who’s on the List?

For the past 6 years, the Internal Revenue Service’s (IRS) Large Business and International (LB&I) Division shifted to a new audit strategy known as “campaigns.” This shift in focus concentrates on examining tax issues that will have the broadest impact on tax compliance while making the most efficient use of IRS’s resources. Given funding issues … Continue reading IRS Updates its Audit “Campaign” Targets – Who’s on the List? →

US Tax Treatment: Stock Options from Your Foreign Employer

With more and more expatriates working outside the United States, many tax questions arise when an employee is given options to buy stock in the foreign company employer.  Stock options are increasingly becoming an important element of the international executive’s compensation package.  There are wonderful opportunities to be had with stock options, but there are … Continue reading US Tax Treatment: Stock Options from Your Foreign Employer →

Taxpayer Wins! Foreign Gift Not Reported: DOJ Concedes he had “Reasonable Cause”

We have had a taxpayer win in the foreign information reporting arena! I provide a summary of the case of Mr. Krzysztof Wrzesinski below.  For readers who wish more, the taxpayer’s complaint is here. Background of the Wrzesinski Case Mr. Wrzesinski (“Taxpayer” or “T”) was a native of Poland who immigrated to the United States … Continue reading Taxpayer Wins! Foreign Gift Not Reported: DOJ Concedes he had “Reasonable Cause” →

Tax Statutes of Limitation – Run Fast, IRS is Right Behind You

With tax season in full swing, now is a good time to review the various civil statutes of limitations (SOL) rules that apply to US tax matters.  Perfect timing to review because we also have a Tax Court case from last month showing how harsh the consequences of the SOL can be if a taxpayer … Continue reading Tax Statutes of Limitation – Run Fast, IRS is Right Behind You →

The Perfect Storm – US Tax, Community Property & the Mobile International Couple  

Last week I blogged about how the US tax system can create serious tax problems for the international couple when one is a US person and the other is not.  In order to keep things simple, it is often advised that the couple hold assets separately to avoid nasty US tax complications. However, in some … Continue reading The Perfect Storm – US Tax, Community Property & the Mobile International Couple   →

More of the Latest:  Digital Asset Reporting for Mr. Taxman @IRS

A survey conducted by CoinLedger of US crypto crypto investors found that only 58% of the sample size reported crypto holdings on their taxes in 2022. That was an improvement of 4% year-over-year. Meanwhile, 31% did not report (11% would not answer).  Let's look at the non-reporters: 50% said the primary reason was that they … Continue reading More of the Latest:  Digital Asset Reporting for Mr. Taxman @IRS →

The Latest: Broker Reporting of Digital Assets and Deducting Crypto Losses

Today’s post provides an update on some important US tax issues relevant to digital assets. While the Internal Revenue Service (IRS) continues its crackdown on digital asset tax reporting, the controversial broker tax reporting rules for digital assets have been postponed. It looks like we will be in for a wait!  Today’s post provides the … Continue reading The Latest: Broker Reporting of Digital Assets and Deducting Crypto Losses →