Oh No! I Have a “Foreign” Pension or Employee Savings Plan and Uncle Sam is Killing Me (Part II)

Part I of this blog post introduced the topic of the "foreign" pension or employee workplace savings plan, and examined in some detail how these plans are becoming more and more popular in the United Arab Emirates. The plans, however, give US expatriate employees some serious US tax headaches. Today's post focusses on these thorny … Continue reading Oh No! I Have a “Foreign” Pension or Employee Savings Plan and Uncle Sam is Killing Me (Part II) →

FinCEN: No FBAR Reporting for Virtual Currency in an Offshore Account

The Internal Revenue Service (IRS) and the Financial Crimes Enforcement Network (FinCEN) will jointly examine application of foreign account reporting requirements to virtual currency held in an offshore account under the Bank Secrecy Act (the notorious FBAR, Form 114). Two important points about FBAR duties for foreign accounts holding virtual currency were made in a … Continue reading FinCEN: No FBAR Reporting for Virtual Currency in an Offshore Account →

IRS: The Grinch Who Stole Christmas

Christmas was on our doorstep not too long ago and was marked by a time of giving and rejoicing. In the employment context, overseas employers with American staff may have been more inclined to be generous in gift-giving, as many of its US employees were away from their Stateside family over the holiday period. The … Continue reading IRS: The Grinch Who Stole Christmas →

Time to Review! Tax Issues for US Recipients of Gifts/Bequests from Foreigners

With Christmas having recently been on our doorstep, now is the time to review what tax consequences are in store for gift givers and their lucky recipients. US tax filings might be required of a US individual who receives a gift (whether in cash or property of some kind - you know, a 5 carat … Continue reading Time to Review! Tax Issues for US Recipients of Gifts/Bequests from Foreigners →

ATTENTION! Married Filing Separately? $5 of Gross Income? Must File US Income Tax Return!

Yes, that did read US$5. Not $50. Not $500……This measly number will heavily impact Americans abroad who are married to non-US spouses. In many instances, the US spouse will file separately and keep the non-US spouse completely out of the US tax picture. This may not always be the best tax strategy but in some … Continue reading ATTENTION! Married Filing Separately? $5 of Gross Income? Must File US Income Tax Return! →

IRS “Relief Procedures for Certain Former Citizens” – Hey! What About Green Card Holders?

In September 2019, the Internal Revenue Service (IRS) announced new Relief Procedures for Certain Former Citizens that will enable certain individuals who relinquished (or are relinquishing) their US citizenship to come into compliance with their US tax and filing obligations. These lucky individuals will not have to pay the back taxes otherwise owed; nor will … Continue reading IRS “Relief Procedures for Certain Former Citizens” – Hey! What About Green Card Holders? →

Dangerous Liaisons: Foreign Assets and the US Nominee

We’ve known for some time that the Internal Revenue Service (IRS) has been mining heaps of data provided to it by financial institutions that were the subject of non-prosecution agreements, as well as examining treasure troves of financial information from various leaks (think “Panama Papers”) looking not only for tax dollars, interest and penalties but … Continue reading Dangerous Liaisons: Foreign Assets and the US Nominee →

US Beneficiary of Foreign Trust: Understanding US Tax Filings

I have written a series of blog posts about foreign (i.e., non-US) trusts and the US tax issues associated with them including the US tax filing and reporting requirements for each of the different players in the foreign trust scenario (creator or "grantor"/"settlor" of the trust), the trustee; and today, the US beneficiary. One of … Continue reading US Beneficiary of Foreign Trust: Understanding US Tax Filings →

IRS Eye on You! Newest Campaign: Repatriation Tax (IRC Section 965)

Most of my readers have heard about Internal Revenue Code Section 965, and the “deemed repatriation” or “transition tax” introduced by the Tax Cuts and Jobs Act (“TCJA”). My earlier blog post provided significant detail about this tax law provision which was intended to move the US international tax regime into a “territorial system”. In making … Continue reading IRS Eye on You! Newest Campaign: Repatriation Tax (IRC Section 965) →

Alimony – No Need for Tax Confusion Even if Paying a Nonresident Alien Individual

My readers know that broad US tax reform was enacted in December 2017 pursuant to the Tax Cuts and Jobs Act (“TCJA”). As of January 1, 2019, the TCJA’s new tax rules impacted any US spouse who was either paying or receiving alimony under a divorce or separation agreement executed after December 31, 2018. Under … Continue reading Alimony – No Need for Tax Confusion Even if Paying a Nonresident Alien Individual →