IRS Determined to Collect FBAR Penalties – “We Have Ways of Making You Pay” … Even if Your Money is Outside the US

The case of US v Schwarzbaum (decided October 26, 2021), discussed in today’s blog post, serves as a harsh reminder of how far the US government will go to collect FBAR penalties. The importance of posting about this latest development is to underscore how aggressive FBAR penalty collection efforts are now becoming. Of course, this case … Continue reading IRS Determined to Collect FBAR Penalties – “We Have Ways of Making You Pay” … Even if Your Money is Outside the US →

Caught in the US Tax Trap: Part I 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? →

IRS Made a Big Announcement – So, Can a Taxpayer Now Rely on IRS FAQ’s?

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? →

Crypto – Harvest Your Tax Losses / Use Offsetting Positions While You Can – Deadline 12/31

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 →

Escaping Tax Penalties – “Reasonable Cause” & Reliance on Professional Advice

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 →

International Taxpayers Need – But Can’t Have an IRS Online Account

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 →

IRS Wants Crypto Information from Foreign Countries

Last week during testimony to the Senate Finance Committee (SFC), US Internal Revenue Service Commissioner (IRS) Charles Rettig stated that Congress needs to provide clear statutory authority in order for the IRS to collect information on cryptocurrency transfers valued over US$10,000. It is believed that such transfers are generally not being reported. Cryptocurrency market capitalization … Continue reading IRS Wants Crypto Information from Foreign Countries →

Pres. Biden: 3d Party Information Reporting to be Increased – Foreign Accounts and Crypto Included

President Biden has an economic agenda and a big part of it is strengthening taxpayer compliance by increasing what must be reported to the Internal Revenue Service (IRS) about client accounts by third party financial institutions and similar entities. The President’s proposal would require information reporting on both business and personal financial accounts. The reporting … Continue reading Pres. Biden: 3d Party Information Reporting to be Increased – Foreign Accounts and Crypto Included →

An Eye for Moving Abroad? Bye-Bye USA, Hello Tax Complications!

Bloomberg Tax - I invite readers to enjoy my recently published article, copied in full below. Reproduced with permission. Published April 20, 2021. The Bureau of National Affairs, Inc. (800-372-1033) http://www.bloombergindustry.com. Daily Tax Report International, published online here and in PDF format here. It has certainly been a year to remember. So many changes have … Continue reading An Eye for Moving Abroad? Bye-Bye USA, Hello Tax Complications! →

FinCEN Moving Quickly to Regulate Beneficial Ownership of US Entities

On April 5th, the Financial Crimes Enforcement Network of the Treasury Department (FinCEN) issued an advance notice of proposed rulemaking (ANPRM) to solicit public comment on questions pertinent to the implementation of the "Corporate Transparency Act" (CTA), enacted into law as part of the National Defense Authorization Act for Fiscal Year 2021. The ANPRM seeks … Continue reading FinCEN Moving Quickly to Regulate Beneficial Ownership of US Entities →