Most of my readers are aware of the “attorney-client privilege”. Generally speaking, the privilege preserves the confidentiality of communications between a lawyer and her clients. When the privilege is in place, attorneys may not divulge their clients’ secrets and cannot be "forced" to divulge them (for example, in a court proceeding or to the Internal … Continue reading Attorney-Client Privilege & John Doe: Your Secret Is Safe … But Your Identity Isn’t!
Tag: angloinfo
OOOPS! I Created a “Foreign” Trust
My earlier blog post set out the tax problems that arise when one has created a "foreign" trust with US beneficiaries. This post will probe the factors used to determine whether a trust is a US trust or a “foreign” trust. It will also point out a possible pitfall for many families who have members … Continue reading OOOPS! I Created a “Foreign” Trust
It’s About Time! Clearer Tax Guidance for Cryptocurrency…. on the Way
Internal Revenue Service (IRS) commissioner Charles Rettig announced that the IRS plans to issue further guidance on the taxation of cryptocurrency. Commissioner Retting wrote that “We have been considering these issues and intend to publish guidance addressing these and other issues soon.” Can it be? Is an "IRS rescue" really on the way? Will it … Continue reading It’s About Time! Clearer Tax Guidance for Cryptocurrency…. on the Way
A No-Go — Foreign Trust with A US Beneficiary
Often, persons living abroad are asked to help care for an elderly parent who lives in the USA. Similar situations can arise for other family members, some of whom may be US citizens living outside of America, but who need assistance due to age or health-related issues. Quite often the care required is simply a … Continue reading A No-Go — Foreign Trust with A US Beneficiary
US Citizenship And Worldwide Taxation: Justified?
Tune in to the amazing debate between John Richardson and Edward Zelinsky, two renowned tax and citizenship professionals, taking place on Friday May 17. Not only is it free, but viewers will receive an unparalleled education about the major issues surrounding US citizenship, its tax consequences for the typical American abroad and Accidental Americans, effects … Continue reading US Citizenship And Worldwide Taxation: Justified?
Outrunning (and Outwitting) the IRS Using the Statute of Limitations
With tax returns either filed, in progress for Americans abroad, put on extension... (or late because an extension was not properly filed), now is a good time to look at the various statutes of limitations (SOL) applicable to US tax matters. What is a tax SOL? Simply, the SOL prescribes the length of time permitted … Continue reading Outrunning (and Outwitting) the IRS Using the Statute of Limitations
Should A Green Card Holder Use the Foreign Earned Income Exclusion?
This is actually a difficult question to answer, despite the fact that many green card holders give little thought to the issue and willy-nilly claim the exclusion. Let's look at some background. Americans working abroad may be eligible to exclude from US taxable income certain foreign earned income (wages, compensation for services) under the rules … Continue reading Should A Green Card Holder Use the Foreign Earned Income Exclusion?
Foreign Life Insurance Policy? Houston, We Have a Problem……
Recently, I blogged about the fact that many US persons living abroad have “foreign” (non-US) life, sickness or accident insurance or a foreign annuity. A mere handful have any knowledge of the complex US tax rules that may apply to these policies. Buzz words include “passive foreign investment company” (PFIC) exposure, Form 114 Bank Secrecy … Continue reading Foreign Life Insurance Policy? Houston, We Have a Problem……
What is a “Bona Fide Resident” for FEIE?
The case of Hudson v. Commissioner, T.C. Memo. 2017-221 provides a valuable lesson from the US Tax Court on what it means to be a "bona fide resident" for purposes of the Section 911 foreign earned income exclusion (“FEIE”). The court in Hudson held that a pilot working for Korean Air and living in a … Continue reading What is a “Bona Fide Resident” for FEIE?
Head’s Up! IRS Just Revised EIN Application Procedure & Foreign Taxpayers Will Struggle
Effective as of May 13, taxpayers can no longer request an employer identification number (EIN) unless the "responsible party" named on the application has either a Social Security Number (SSN) or Individual Taxpayer Identification Number (ITIN). Only governmental entities and the military are exempt from this requirement, and may continue to list non-individual entities as … Continue reading Head’s Up! IRS Just Revised EIN Application Procedure & Foreign Taxpayers Will Struggle
Virginia - US TAX TALK 