“Qualified Dividend Income”: How do the Rules Apply to “Controlled Foreign Corporations?” (Part I)

Today’s post continues to explore the interplay between foreign corporations and the US shareholder’s ability for lower tax rates available only for "qualified dividends". It's a complicated topic. Not all dividends are treated the same and the nuances can make a big difference to the taxpayer’s ultimate investment return. As detailed in my earlier blog … Continue reading “Qualified Dividend Income”: How do the Rules Apply to “Controlled Foreign Corporations?” (Part I) →

Tis the Season! Giving / Getting Gifts from a Foreign Entity?

Holidays are soon upon us, and many people will be making gifts to family and friends. It is very common to make gifts of cash – typically sending funds from a bank account to the recipient’s account. When gifts are made by foreign persons to US persons, there are many US tax traps for both … Continue reading Tis the Season! Giving / Getting Gifts from a Foreign Entity? →

Billionaires Income Tax On the Way & Covered Expats are Hit Hardest of All

If you or your clients are really (really) wealthy (more than $100 million in annual income or more than $1 billion in assets) and thinking about expatriation (relinquishing US citizenship or a green card as a long-term resident), the time is now. Even if not super wealthy, the newly proposed Billionaires Income Tax should serve … Continue reading Billionaires Income Tax On the Way & Covered Expats are Hit Hardest of All →

Tax Planning – “Foreign/International” Annual Inflation Adjustments Coming in 2024

Revenue Procedure 2023-34 was released by the IRS on November 9, 2023. It provides full details about the annual inflation adjustments that are important in the world of US tax and impact over 60 tax provisions in the Internal Revenue Code ("Code"), including tax rate schedules and many other tax changes. Tax pro’s have been … Continue reading Tax Planning – “Foreign/International” Annual Inflation Adjustments Coming in 2024 →

The New York Times, USSCt Justice Clarence Thomas, Juicy Gifts & the Tax Lessons!

Sometimes I like to bring up issues occurring strictly in the USA and take a peek at how the US tax rules would shake out if foreigners were involved in the transactions. It always makes for a much more complicated analysis. Here is one for today! Let’s look at the juicy story of Justice Clarence … Continue reading The New York Times, USSCt Justice Clarence Thomas, Juicy Gifts & the Tax Lessons! →

Tax Court Petition Filed Late? Taxpayer Beats the Clock with Third Circuit Decision

You may remember from my last post that for the Swiss (I know them so well, being married to one for almost 4 decades), punctuality is not merely a nicety, or a bonbon in the huge dessert buffet of life. Punctuality is highly valued and de rigueur. So it is with the US tax rules when … Continue reading Tax Court Petition Filed Late? Taxpayer Beats the Clock with Third Circuit Decision →

Is the US Tax Court Swiss? Taxpayer Loses When Petition Filed 11 Seconds Late

I’ve been married to a Swiss for almost 40 years. I know the critical importance of timeliness. When you say “I’ll be ready in 5 minutes”, believe me, that Swiss watch is ticking. And, so it is with the Tax Court and filing a Tax Court petition in response to an Internal Revenue Service (IRS) … Continue reading Is the US Tax Court Swiss? Taxpayer Loses When Petition Filed 11 Seconds Late →

TikTok’s (Wrong) Tax Advice and How the Trust Tax Rules Really Work

My earlier post describing TikTok tax advice as to the magical workings of the “Non-Grantor Irrevocable Complex Discretionary Spendthrift Trust” (NGICDST) proved highly popular. The NGICDST is being marketed heavily on social media platforms and certain business websites. After the Internal Revenue Service (IRS) discovered the promotional material, the agency shut down any notion that … Continue reading TikTok’s (Wrong) Tax Advice and How the Trust Tax Rules Really Work →

US Tax Issues Abound: A Global Look at Protecting Vulnerable Persons from Financial Fraud (The Case of the Wicked Stepdaughter)

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) →

Do I Have Worldwide US Tax Liability While Waiting for the Certificate of Loss of Nationality (CLN)?

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)? →