Virginia La Torre Jeker, J.D. — US tax matters affecting international clients
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
The 3.8% Medicare surcharge, more commonly called the “Net Investment Income Tax” or (“NIIT”), was enacted to help fund “Obamacare” health coverage. It is imposed on “high wage earners” but because the NIIT thresholds are not subject to inflation, the rules are now grabbing more and more taxpayers. President Biden’s Green Book proposals if enacted … Continue reading “Net Investment Income Tax” is Hitting More Taxpayers … Americans Abroad Really Feeling the Pinch
On Wednesday I presented a webinar for the Financial Planning Association’s July International & Cross-Border Planning Knowledge Circle. My webinar highlighted numerous US tax issues when safeguarding the finances of the elderly (or other vulnerable individuals), whether Stateside or overseas. You can listen to the entire webinar here. The Case of the Wicked Stepdaughter A … Continue reading US Tax Issues Abound: A Global Look at Protecting Vulnerable Persons from Financial Fraud (The Case of the Wicked Stepdaughter)
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!
My earlier blog post covered some US tax issues faced by the individual granted options on foreign company stock by his non-US employer. When it comes to foreign information return reporting, the grant of options to an employee on foreign stock can get confusing. Is an option granted to an employee with respect to foreign … Continue reading FATCA Reporting of Compensatory Foreign Stock Option on Form 8938
On May 23, a decision (Decision) by the Belgian Data Protection Authority (BDPA) now prohibits the Belgian tax authorities (the defendant in this case) from transferring to the Internal Revenue Service (IRS) the personal data of Belgian “Accidental Americans” (and likely other US persons with accounts in Belgium) pursuant to the ”FATCA” Intergovernmental Agreement between … Continue reading Belgium Fights Back! No FATCA Info to IRS – Deep Dive the Belgian Decision
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?
Understanding the US gift tax is important for both US and non-US persons. It comes as a big surprise to many people that US gift tax issues can arise in many unanticipated ways, such as sending money to an adult child attending college; making loans interest-free to family members or giving them loans with below-market interest rates. Even non-US persons can … Continue reading Foreign Persons Making Gifts to the US – Cash / Wire Transfers / Checks?
Virginia - US TAX TALK 