You may remember my earlier blog post detailing the unenviable case of the wealthy New York Seggerman family which had undisclosed offshore bank accounts inherited from their father. Instead of coming clean and revealing the existence of the accounts to the US Internal Revenue Service (IRS), four of the Seggerman siblings created even more secret … Continue reading A Dangerous Game: Jail Time for Inherited Foreign Accounts
Category: Reporting Rules
Getting an ITIN When Overseas: Help!
Today's post looks at the US Internal Revenue Service (IRS) options available to taxpayers residing abroad who need an “Individual Taxpayer Identification Number” (ITIN) to fulfill their US tax filing duties. There are 3 basic options (i) mailing the completed Form W-7, “Application for Individual Taxpayer Identification”, and required identification documents to the IRS (ii) … Continue reading Getting an ITIN When Overseas: Help!
Corporate Veil Dropping: British Crown Dependencies Make Beneficial Ownership Registers Public, US Takes Baby Steps
Why should anyone care about government-mandated beneficial ownership registers for legal entities? Why might a multinational enterprise have concerns with such registers? Current news tells us more and more of them are in the works. After years of dragging their heels, and to the surprise of many in the international community, the British Crown Dependencies … Continue reading Corporate Veil Dropping: British Crown Dependencies Make Beneficial Ownership Registers Public, US Takes Baby Steps
US Tax Filings by US Grantor of Foreign Trust
Today's post is a continuation of a series of blog posts dealing with foreign trusts A general overview of the US tax issues surrounding foreign trusts can be found here. When a US person is involved in any way with a foreign trust extra caution is required. Strict US tax filing responsibilities come into play … Continue reading US Tax Filings by US Grantor of Foreign Trust
No Creation of US Companies or LLCs Without Disclosure! Your Name, Please – Corporate Transparency Act of 2019
Each year, almost 2,000,000 corporations and limited liability companies are being formed under the laws of the various United States. Yet, only a handful of States require information about the beneficial owners of the corporations and limited liability companies formed under their laws. A person forming a corporation or limited liability company within the US … Continue reading No Creation of US Companies or LLCs Without Disclosure! Your Name, Please – Corporate Transparency Act of 2019
Americans Overseas: Timely Filing of Tax Returns and Other Documents With the IRS
Quite often, US taxpayers living in a foreign country are faced with tight deadlines for filing their paper tax returns. They are often confused as to how to send these physical documents to the Internal Revenue Service (IRS) and be considered to have sent them in a timely fashion when the foreign (i.e., non-US) post … Continue reading Americans Overseas: Timely Filing of Tax Returns and Other Documents With the IRS
OOOPS! I Created a “Foreign” Trust
My earlier blog post set out the tax problems that arise when one has created a "foreign" trust with US beneficiaries. This post will probe the factors used to determine whether a trust is a US trust or a “foreign” trust. It will also point out a possible pitfall for many families who have members … Continue reading OOOPS! I Created a “Foreign” Trust
US Citizenship And Worldwide Taxation: Justified?
Tune in to the amazing debate between John Richardson and Edward Zelinsky, two renowned tax and citizenship professionals, taking place on Friday May 17. Not only is it free, but viewers will receive an unparalleled education about the major issues surrounding US citizenship, its tax consequences for the typical American abroad and Accidental Americans, effects … Continue reading US Citizenship And Worldwide Taxation: Justified?
Outrunning (and Outwitting) the IRS Using the Statute of Limitations
With tax returns either filed, in progress for Americans abroad, put on extension... (or late because an extension was not properly filed), now is a good time to look at the various statutes of limitations (SOL) applicable to US tax matters. What is a tax SOL? Simply, the SOL prescribes the length of time permitted … Continue reading Outrunning (and Outwitting) the IRS Using the Statute of Limitations
Should A Green Card Holder Use the Foreign Earned Income Exclusion?
This is actually a difficult question to answer, despite the fact that many green card holders give little thought to the issue and willy-nilly claim the exclusion. Let's look at some background. Americans working abroad may be eligible to exclude from US taxable income certain foreign earned income (wages, compensation for services) under the rules … Continue reading Should A Green Card Holder Use the Foreign Earned Income Exclusion?








