PODCAST! Crash Course Info! Renouncing US Citizenship / Relinquishing Green Card – Beware The Exit Tax and More

A very informative podcast - I would say it's a crash course on the US #expatriation regime including the recently issued final IRS regs on the Sec. 2801 transfer tax, lots of tax tips including gifting issues to get below USD 2 million threshold, what NOT TO DO if CBP wants you to sign I-407 … Continue reading PODCAST! Crash Course Info! Renouncing US Citizenship / Relinquishing Green Card – Beware The Exit Tax and More

40% Transfer Tax: IRS Final Say On Foreign Gifts, Bequests From “Covered Expatriates”

Seventeen years after Congress enacted IRC Section 2801, the IRS (finally) released final regulations implementing the law on January 10, 2025.  It’s been a long wait. The regulations clarify (to a certain extent) the tax implications for U.S. persons receiving certain gifts and bequests from former U.S. citizens and long-term resident green card holders. At its … Continue reading 40% Transfer Tax: IRS Final Say On Foreign Gifts, Bequests From “Covered Expatriates”

U.S. Estate Tax Treaties – Help For Foreigners But Not U.S. Citizens

Foreign investors with assets in the United States often encounter complex estate tax rules that can significantly impact taxation of their U.S. assets at death.  If the individual is a non-resident, non-citizen of the U.S. (NRNC), the U.S. estate tax applies only to assets situated or deemed to be situated within the U.S. (for example, … Continue reading U.S. Estate Tax Treaties – Help For Foreigners But Not U.S. Citizens

Breaking! Residence-Based Taxation for Americans Abroad May Become Reality

Representative Darin LaHood just introduced on December 18 the Residence-Based Taxation for Americans Abroad Act, aiming to modernize the US tax system for Americans living overseas. This proposal seeks to shift from the current citizenship-based taxation—which taxes US citizens on their worldwide income regardless of residence—to a residency-based system. The existing US tax framework has … Continue reading Breaking! Residence-Based Taxation for Americans Abroad May Become Reality

Late Form 3520 Foreign Gifts And Bequests, Good News From IRS

The IRS Commissioner Danny Werfel announced some good news for taxpayers at the end of October 2024. The IRS has ended its practice of automatically assessing penalties when a taxpayer voluntarily submits a late Form 3520, Part IV. This form deals with the obligation of U.S. persons to report to the IRS the receipt of … Continue reading Late Form 3520 Foreign Gifts And Bequests, Good News From IRS

Bitcoin Jesus Challenges Constitutionality Of Expatriation “Exit Tax”

Roger Ver, an early Bitcoin investor renowned as “Bitcoin Jesus” for his evangelism of cryptocurrency since 2011, now finds himself in a legal maelstrom. Ver, a controversial figure in the blockchain world, was arrested in April 2024 in Spain on U.S. criminal charges stemming from allegations of mail fraud, tax evasion, and filing false tax … Continue reading Bitcoin Jesus Challenges Constitutionality Of Expatriation “Exit Tax”

Americans Living Abroad: Foreign Housing Tax Break, Explained

Overseas Americans are entitled to certain tax breaks assuming various qualifications are met. One of the significant tax breaks is the ability to exclude from taxable income certain amounts provided by an employer for foreign housing. Housing costs are “personal” in nature and the tax laws do not provide exclusions or deductions for personal expenditures. A … Continue reading Americans Living Abroad: Foreign Housing Tax Break, Explained

Surrender Green Card At The Border: Form I-407, U.S. Tax Expatriation

U.S. immigration law assumes that a person admitted to the United States as a lawful permanent resident (green card holder) will live there permanently. Remaining outside the United States for an extended period, may possibly result in a loss of LPR status. Long periods spent outside of America can result in problems upon re-entry at the … Continue reading Surrender Green Card At The Border: Form I-407, U.S. Tax Expatriation

IRS Tax Records, Foreign Assets: When (And What) To Keep Or Toss

Many people face the dilemma of what to do with old tax returns and supporting paperwork, often wondering when it’s safe to discard them. However, determining the right time can be tricky, especially for taxpayers with foreign assets. Those with overseas financial interests must pay particular attention for several reasons, including expanded statutes of limitation … Continue reading IRS Tax Records, Foreign Assets: When (And What) To Keep Or Toss

Need an FBAR Escape Hatch?

The Report of Foreign Bank and Financial Accounts (FinCEN Form 114) commonly called the FBAR is a crucial reporting requirement for US persons (citizens, green card holders and those meeting the substantial presence test) with foreign financial accounts. With the deadline for the 2023 FBAR set for October 15, my Forbes article provides information to … Continue reading Need an FBAR Escape Hatch?