Virginia La Torre Jeker, J.D. — US tax matters affecting international clients
Last week I blogged about the US income tax issues that plague a US partnership when it has a foreign partner. That post showed things can get ugly when a US partnership has a foreign partner. The post got a lot of views and feedback so it is evidently a topic of interest. I thought … Continue reading Tax Things Get Ugly for Foreigners When a Foreign Partnership has a US Partner
When non-US persons invest in US assets, the investment structure should be considered well in advance. In many instances, foreign investors using US-based entities for investment are blissfully unaware of the tax pitfalls with regard to the structure chosen. The tax ramifications typically involve US income and US estate tax exposure. Foreign investors must nail … Continue reading Investing in a US Partnership? – A Bevy of Tax Issues for the Foreign Investor
My earlier post describing TikTok tax advice as to the magical workings of the “Non-Grantor Irrevocable Complex Discretionary Spendthrift Trust” (NGICDST) proved highly popular. The NGICDST is being marketed heavily on social media platforms and certain business websites. After the Internal Revenue Service (IRS) discovered the promotional material, the agency shut down any notion that … Continue reading TikTok’s (Wrong) Tax Advice and How the Trust Tax Rules Really Work
Part I of my blog post set out the background and discussed the debate over Internal Revenue Code Section 965 “transition tax” or “mandatory repatriation tax” enacted in 2017. The Supreme Court recently decided to review the 9th Circuit case of Moore v. United States bringing this controversial tax back into the spotlight. The Court … Continue reading Should You File a Protective Refund Claim for the Transition Tax While Waiting for the US Supreme Court? Moore Might Mean More!
This will be a very short post with a few simple lessons I have shared before: Fast tax advice, is like fast fashion. A waste! It's all too often a big mistake with serious repercussions. If something sounds too good to be true, it is. So, if you have not heard of it yet, today’s … Continue reading Beware TikTok Tax Advice – IRS Tanks a Trust Scheme
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
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)?
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!
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?
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
Virginia - US TAX TALK 