Tag: Americans Overseas

Death of the American Abroad – Is the Estate a US or Foreign Estate? What to do with Undeclared Foreign Assets?

With more and more Americans living and working abroad, the reality is that US persons will also pass away while residing in a foreign country. Did you know that a US citizen residing abroad at death may have a “foreign estate” for US income tax purposes?  What does that mean for the estate? What does … Continue reading Death of the American Abroad – Is the Estate a US or Foreign Estate? What to do with Undeclared Foreign Assets? →

Social Security Benefits Paid to US and Non-US Individuals, Including Those Who Expatriated – How Are They Taxed?

A portion of an individual’s US Social Security retirement, survivors, or disability benefits may be subject to Federal Income tax, regardless if the individual is a US or non-US person. Today’s post looks at the US taxation details on US social security benefits for US and non-US persons.  My earlier blog post here discussed the … Continue reading Social Security Benefits Paid to US and Non-US Individuals, Including Those Who Expatriated – How Are They Taxed? →

US Tax – Safeguarding Finances of the Elderly, Stateside and Abroad

My latest article is copied below in full, as published by Bloomberg Tax, December 9, 2022 in Tax Insights, reproduced with permission, link here.The Bureau of National Affairs, Inc. (800-372-1033) http://www.bloombergindustry.com The growing trend of email and phone scammers, combined with the potential for diminished cognitive abilities due to aging, can imperil elderly people’s financial … Continue reading US Tax – Safeguarding Finances of the Elderly, Stateside and Abroad →

Foreign Assets — How Can the IRS Enforce Tax Collection Overseas? (Part II)

Last week's blog post, here, examined some of the weapons the Internal Revenue Service (IRS) can use to collect taxes when the uncooperative taxpayer and assets are located abroad.  Today we look at some other possible remedies. Is There Any US Connection to Foreign Banks? The IRS can issue a levy notice to any bank … Continue reading Foreign Assets — How Can the IRS Enforce Tax Collection Overseas? (Part II) →

Foreign Assets — How Can the IRS Enforce Tax Collection Overseas? (Part I)

Generally speaking, it is not an easy process for the US government to seize assets overseas in order to satisfy a taxpayer's tax debts.  The Internal Revenue Service (IRS) has to follow certain procedures to collect taxes.  If they are assessed against a US or non-US taxpayer, assuming the person is overseas and has no … Continue reading Foreign Assets — How Can the IRS Enforce Tax Collection Overseas? (Part I) →

What is a Closing Agreement and When Will One Be Entered Into by the IRS?

Last week's blog post, here, discussed the details of the Internal Revenue Service "Voluntary Disclosure Practice" (VDP).  VDP is the one and only method for voluntary disclosures that apply to criminal tax activity, regardless if the activity involves offshore issues or strictly domestic ones.  The final conclusion of a taxpayer’s entry into the Voluntary Disclosure … Continue reading What is a Closing Agreement and When Will One Be Entered Into by the IRS? →

US Tax Inflation Adjustments for 2023 – Impact on the International Family

Certain provisions in the United States Internal Revenue Code (Code) are tied to inflation to prevent rising prices from resulting in higher taxes. Annual inflation adjustments have been part of the tax rules for well over 2 decades. These formulas set by Congress help prevent inflation from nudging taxpayers into higher tax brackets and increasing … Continue reading US Tax Inflation Adjustments for 2023 – Impact on the International Family →

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…. →

Mr. FBAR – He Lurks in Every Corner – Katholos Case Expands Meaning of “Financial Interest”

We have another important FBAR case. The case is significant for 2 distinct reasons 1) clarification, and some may say, an ‘expansion’ of the definition of “financial interest” in an account requiring FBAR reporting and 2) a firm demonstration how far the Internal Revenue Service (IRS) will go to assert a civil “willful” FBAR penalty. … Continue reading Mr. FBAR – He Lurks in Every Corner – Katholos Case Expands Meaning of “Financial Interest” →

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) →