Exciting Update: Revamped US Tax Primer for Expats & Global Citizens + Must-Watch YouTube Interviews!

Hello subscribers, global go-getters, expats, and anyone navigating the maze of US taxes abroad! I've got some exciting updates that'll make your financial life smoother and your dreams of living overseas a whole lot less taxing. First, I just rolled out a complete refresh of my flagship US Tax Primer for American Expatriates Worldwide and … Continue reading Exciting Update: Revamped US Tax Primer for Expats & Global Citizens + Must-Watch YouTube Interviews! →

Unfiled Tax Returns Can Lead To An IRS Action That Costs You Money

With tax filing season in full swing, it’s important to understand what might happen if you do not file a U.S. income tax return. The IRS can, and often will, file a “substitute” return for you and generally, it won’t be favorable. Taxpayers living and working abroad face greater risks with a SFR. The IRS … Continue reading Unfiled Tax Returns Can Lead To An IRS Action That Costs You Money →

Post-Bittner, IRS Gets Tougher on “Nonwillful” FBAR Penalties

As predicted, the fallout from the United States Supreme Court decision in Bittner v. United States, means a tougher stance by the Internal Revenue Service (IRS) when it comes to reducing so-called “FBAR” penalties for “nonwillful” violations. In a nutshell, the Bittner court held that the Bank Secrecy Act (BSA) $10,000 maximum penalty for the … Continue reading Post-Bittner, IRS Gets Tougher on “Nonwillful” FBAR Penalties →

Overseas Americans: Fast Facts About Amending a US Income Tax Return

Soon enough thoughts will turn to preparing US tax returns for 2022. Thorough preparation should at least include a review of the tax return filed for the prior tax year. In doing this, it often happens that taxpayers discover an error occurred in filing a prior year’s return. If an error is discovered, it may … Continue reading Overseas Americans: Fast Facts About Amending a US Income Tax Return →

IRS is Ruthless in Seeking “Willful” FBAR Penalties – But the Court Won’t Have it….

We have another important FBAR case, US v Katholos No17cv531 WDNY Aug 10 2022. Ms Katholos was first introduced to my readers in 2018 (blog post here). An update on Katholos was posted just last week detailing a court’s clarification, perhaps an expansion, of the definition of “financial interest” in an account requiring FBAR reporting. … Continue reading IRS is Ruthless in Seeking “Willful” FBAR Penalties – But the Court Won’t Have it…. →

Are Streamlined Audits Becoming More Common? The Streamlined Submission that went Belly-Up (Part II)

Are "Streamlined" audits on the rise? It appears so. In 2016, two years after the Streamlined Procedures were put into place, then-Acting Assistant Attorney General Caroline Ciraolo (Dept. of Justice) had this to say in an interview: "After seven years of voluntary disclosure programs, nearly 200 criminal prosecutions, and the increased assessment and suits to … Continue reading Are Streamlined Audits Becoming More Common? The Streamlined Submission that went Belly-Up (Part II) →

What Can Happen if Your Streamlined Submission Goes Belly-Up? (Part I)

The IRS Streamlined Procedure, whether the Streamlined Foreign Offshore Procedure (SFOP) or the Streamlined Domestic Offshore Procedure (SDOP) of 2014 is still available for taxpayers, but the Internal Revenue Service (IRS) is apparently closely policing those who enter the program. The IRS is now very carefully vetting the cases coming in. A hallmark of the … Continue reading What Can Happen if Your Streamlined Submission Goes Belly-Up? (Part I) →

Foreign Accounts and Assets: How I Approach a “Streamlined” Tax Filing Nowadays

The Internal Revenue Service (IRS) Streamlined Procedures of 2014 are still available for taxpayers with tax noncompliance issues that involve unreported income from a foreign financial asset. The Procedures can help taxpayers who have not filed certain information returns associated with the foreign asset (e.g., Form 8938; Form 5471 pertaining to ownership in a foreign … Continue reading Foreign Accounts and Assets: How I Approach a “Streamlined” Tax Filing Nowadays →

FBAR – Fifth Circuit, Non-Willful Penalty Multiplies “Per Account” in Bittner Case

Ka’Ching! It’s a win for the Internal Revenue Service (IRS)! At the end of November, in United States v. Bittner, (No. 20-4059, 5th Cir. 11/30/21), the Fifth Circuit overruled the lower court and held that the FBAR non-willful US$10,000 penalty applies on a per account rather than a per form basis. The taxpayer was hit … Continue reading FBAR – Fifth Circuit, Non-Willful Penalty Multiplies “Per Account” in Bittner Case →

Is IRS Finally Seeing the Light on Foreign Information Returns?

Bloomberg Tax - I invite readers to enjoy my recently published article, copied in full below. Reproduced with permission. Published December 3, 2021. The Bureau of National Affairs, Inc. (800-372-1033) http://www.bloombergindustry.com published in Tax Insights and Commentary News, online here. Various options are available to correct the problem of missing information returns for U.S. … Continue reading Is IRS Finally Seeing the Light on Foreign Information Returns? →