Taxpayer’s FBAR WIN: “Willful” Penalty over $9.8 Million for Mere Signature Authority — Removed Entirely

Today’s post involving the case of Jonathan Zuhovitzky presents some important takeaways:  The IRS can get very aggressive when it comes to assessing “willful” FBAR penalties. We see this trend is on the rise. A diligent representative, however, can get the IRS to settle an FBAR matter that is favorable to the taxpayer.  It takes … Continue reading Taxpayer’s FBAR WIN: “Willful” Penalty over $9.8 Million for Mere Signature Authority — Removed Entirely

Selecting a Trustee for Your US Trust – What About a  Foreign Family Member?

Many parents establish a trust for their children and intend that the trust be a domestic (US) trust. Often, this will be a testamentary trust. That is, one that comes into being upon death of the testator, created pursuant to a Last Will & Testament.  Many parents struggle with the decision as to who to … Continue reading Selecting a Trustee for Your US Trust – What About a  Foreign Family Member?

Renouncing One’s US Citizenship: More Audits, Virtual Currency, CLN & Travel

COVID-19 restrictions have severely limited services at US embassies and consulates around the world. As a result, renouncing one’s US citizenship has become very difficult, and in many cases, just about impossible at the current time. This gives individuals more time to make sure they have properly planned for expatriation. It's a big step. I … Continue reading Renouncing One’s US Citizenship: More Audits, Virtual Currency, CLN & Travel

What does Senator Warren’s Proposed Wealth Tax Mean for You?

The ‘‘Ultra-Millionaire Tax Act of 2021’’ (the “Act”) was proposed by Democratic Senators Elizabeth Warren and Bernie Sanders on March 1, 2021.  Like all other tax proposals I have seen in my over 35+ years of tax practice, once the bee is in the bonnet, legislation will inevitably, inexorably, eventually blossom and flourish.  The Act … Continue reading What does Senator Warren’s Proposed Wealth Tax Mean for You?

Dubai:  Combine your Renunciation with a Vacation  

UPDATE:  Sadly - the US Consulate in Dubai has just informed me that they cannot accept appointments for non-emergency services for non-UAE residents.  Expatriation is considered a non-emergency to them, although I feel sure the individual wishing to expatriate would disagree. I have requested the Consulate to update me if the situation changes.   Welcome … Continue reading Dubai:  Combine your Renunciation with a Vacation  

Where Do You Live?  IRS Announces 2021 Foreign Housing Cost Amounts

The Internal Revenue Service (IRS) just issued Notice 2021-18.  This is the geographical list that spells out adjustments to the foreign housing exclusion available for many US persons living abroad. These limitations are made on the basis of geographic differences in housing costs relative to housing costs in the United States.  The ability to deduct … Continue reading Where Do You Live?  IRS Announces 2021 Foreign Housing Cost Amounts

REMINDER: FBAR Fears? We Have You Covered!

Please spread the word and share this news. Empower yourself. Knowledge is your best weapon. WHO: Virginia La Torre Jeker, J.D., will be making FBAR matters simple in a cost-effective live online training session along with, Jimmy Sexton, LL.M. a fellow international tax expert.  Virginia is admitted to the New York Bar since 1984, as … Continue reading REMINDER: FBAR Fears? We Have You Covered!

Third Party Reporting of Virtual Currency: Who’s Telling the IRS What?

Many of my readers are aware that I have written various blog posts about the US tax issues that surround virtual currency. Some have asked, (perhaps innocently, perhaps not), about so-called “third party reporting” of virtual currency to the Internal Revenue Service (IRS) .  For those who do not know what this means – it’s … Continue reading Third Party Reporting of Virtual Currency: Who’s Telling the IRS What?

No IRS! The Sky is NOT the Limit….MAJOR FBAR WIN! Penalty is Per FBAR Form, Not Per Account

As all my readers know, the Bank Secrecy Act (BSA) has been requiring US taxpayers to report certain foreign financial accounts and retain detailed records about them.  Failing to file or to properly report all foreign accounts on the notorious “FBAR” (FinCEN Form 114, Report of Foreign Bank and Financial Accounts) can result in very high … Continue reading No IRS! The Sky is NOT the Limit….MAJOR FBAR WIN! Penalty is Per FBAR Form, Not Per Account