D is for “Domicile”, Don’t Disregard!

Several of my recent blog posts set the stage showcasing the serious US tax issues that can arise for a married couple when only one  is a US person and they are impacted by application of a foreign country’s community property laws.  You can read these blog posts here, here and here. For example, if funding … Continue reading D is for “Domicile”, Don’t Disregard!

Ground-Breaking Development: IRS “Amnesty” Relief for Certain Expatriates!

The Internal Revenue Service (IRS) announced today new Relief Procedures for Certain Former Citizens that will enable certain individuals who relinquished their US citizenship to come into compliance with their US tax and filing obligations. These lucky individuals will not have to pay the back taxes otherwise owed, or any penalties or interest!  It sounds … Continue reading Ground-Breaking Development: IRS “Amnesty” Relief for Certain Expatriates!

Head’s Up! Foreign-Owned Single Member US LLC: Increase in Penalties for Form 5472

My earlier blog post covered some basics about Form 5472, including how the Form helps the US Internal Revenue Service (IRS) learn about foreign-owned businesses in the US and when to audit them, the meanings of certain terms such as what is meant by a “reportable transaction” with a “related party”, and the situation requiring filing … Continue reading Head’s Up! Foreign-Owned Single Member US LLC: Increase in Penalties for Form 5472

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

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”

MORE Real Life Examples: US Tax Traps of International Community Property

Part I of my blog post explained the basics of community property and how US tax laws can override certain community property principles when a US/NRA married couple is involved.  This was followed by a blog post posing a smattering of real-life examples that demonstrated how community property laws can impact the US tax situation … Continue reading MORE Real Life Examples: US Tax Traps of International Community Property

Real Life Examples: A US Tax Mess, International Community Property

Attention all mixed nationality couples, with one spouse having US citizenship or US resident status while the other is a nonresident alien (NRA)!  Your tax advisor should be looking at all possible issues surrounding your fact pattern.  If you live in a foreign jurisdiction or US state (there are 9 of them) with a community … Continue reading Real Life Examples: A US Tax Mess, International Community Property

US Tax Perils of International Community Property

US tax liabilities and requirements to file US tax and information returns are impacted by community property laws that exist in many foreign countries across the globe.  Today’s blog post will examine some of these issues and set the stage for upcoming posts dealing with community property in the international context and how it affects … Continue reading US Tax Perils of International Community Property