Americans Abroad: Taxpayer GILTI Victory Just Announced in Proposed Regulations!

The Internal Revenue Service (IRS) just issued proposed Regulations dealing with the “Deduction for Foreign-Derived Intangible Income and Global Intangible Low-Taxed Income (“GILTI”)”. The proposed regulations mark a big win for Americans running their businesses through foreign corporations. The regulations are scheduled to be published in the Federal Register tomorrow. In part, they address the … Continue reading Americans Abroad: Taxpayer GILTI Victory Just Announced in Proposed Regulations! →

QBI Deduction? Not for the American Abroad! AND Next Year, IRS Will Be Checking Your Numbers!

Section 199A of the Internal Revenue Code was created by the Tax Cuts and Jobs Act (TCJA). If a taxpayer can utilize the new law, the taxpayer can save a bundle in taxes since the provision provides a 20% deduction for so-called “qualified business income” ("QBI”). The American abroad will not be so lucky since … Continue reading QBI Deduction? Not for the American Abroad! AND Next Year, IRS Will Be Checking Your Numbers! →

Americans Abroad – How to Cope With Tax Reform & Save for Education

President Trump’s tax reform (commonly referred to as the "Tax Cuts and Jobs Act", and also known as "TCJA" was signed into law on December 22, 2017. My recent blog post detailed how TCJA revised the “kiddie tax” rules and how the new rules will take a big bite out of a young person’s investment income, … Continue reading Americans Abroad – How to Cope With Tax Reform & Save for Education →

Hot off the Press: IRS User-Friendly Guides Explain TCJA Basics

Tax simplification was an enunciated goal of the Tax Cuts and Jobs Act (TCJA) enacted in December 2017... but it was certainly a goal that remains unmet. The Internal Revenue Service (IRS) itself has estimated that due to TCJA it needs to create or revise more than 400 taxpayer forms, instructions and publications for the … Continue reading Hot off the Press: IRS User-Friendly Guides Explain TCJA Basics →

Americans Overseas – Tax Filing Due Dates and Payment Options

As the April tax filing due date looms, many US persons living abroad are finishing up their US tax returns and getting ready to pay the taxman. First of all, what is the tax filing due date in 2019? When to File Generally, the federal income tax return and tax payment are due April 15—unless … Continue reading Americans Overseas – Tax Filing Due Dates and Payment Options →

Your Children, Kiddie Tax and US Tax Reform – Tax, Tax, Tax the Kiddies!

Giving a significant amount of investment assets to one’s children used to be a popular tax strategy, since it permitted the income earned on the investment to be taxed at the child’s presumably lower tax rate. Congress, in its kind-hearted way enacted the so-called “kiddie tax” in 1986 to prevent parents from abusing this strategy. … Continue reading Your Children, Kiddie Tax and US Tax Reform – Tax, Tax, Tax the Kiddies! →

The #FBAR Marriage – A Troublesome Union

I was just recently interviewed on Canadian TV in 3 different sessions covering the US tax complications when a US person and non-US person are married (US income tax, gift tax, estate tax). I am being interviewed by John Richardson, a Canadian and US attorney. John calls this phenomenon the #FBARMarriage. Some marriages don't last -- … Continue reading The #FBAR Marriage – A Troublesome Union →

Property Transfers at Divorce and the Foreign (Non-US) Spouse

As if divorce were not a stressful enough time, the complexities of the US tax rules when a non-US spouse is involved just make it all the more unbearable. Keep in mind, too, that foreign divorces can add further legal complexity to the mix and professional help should always be sought. This is so because when foreign … Continue reading Property Transfers at Divorce and the Foreign (Non-US) Spouse →

Mechanics of the Substantial Presence Test and Exemptions: Foreign Teacher, Student, Trainee, Government Employee in the US

Once a non-US individual is classified for income tax purposes as a “resident” he is subject to income tax in the same manner as a US citizen: i.e., taxed on his worldwide income (meaning income from all sources whether from within or outside the US) at a maximum rate of 37 percent (this top rate … Continue reading Mechanics of the Substantial Presence Test and Exemptions: Foreign Teacher, Student, Trainee, Government Employee in the US →

Tax Court, IRS Speak with Forked Tongue? Section 6013(g) Election to Treat Foreign Spouse as US “Resident”

I have written a few blog posts on the thorny side of filing US income tax returns, FBARs and various information returns when one is married to a non-resident alien (NRA) spouse. It may be helpful to read those posts here and here before embarking on this one as the earlier posts set out some … Continue reading Tax Court, IRS Speak with Forked Tongue? Section 6013(g) Election to Treat Foreign Spouse as US “Resident” →