Am I Being Cynical? Serious Problems Acknowledged -Too Little, Too Late for Taxpayers Outside the US

The Taxpayer Advocate Service (TAS) recently released its 2022 report to Congress. In one portion of the Report (listed in “Most Serious Problems Encountered by Taxpayers” #10 OVERSEAS TAXPAYERS: Taxpayers Outside of the United States Face Significant Barriers to Meeting Their U.S. Tax Obligations) TAS provided a succinct review of the problems faced by American … Continue reading Am I Being Cynical? Serious Problems Acknowledged -Too Little, Too Late for Taxpayers Outside the US →

Treaty Tie-Breaker: Oh the Pitfalls Beware!

The United States is unique in its approach to taxing individuals who are US citizens or lawful permanent residents (green card holders). Such individuals are taxed on worldwide income regardless of where they may reside. On account of this taxation approach, US citizens and green card holders who live outside of America may be subject … Continue reading Treaty Tie-Breaker: Oh the Pitfalls Beware! →

Overseas Americans: Fast Facts About Amending a US Income Tax Return

Soon enough thoughts will turn to preparing US tax returns for 2022. Thorough preparation should at least include a review of the tax return filed for the prior tax year. In doing this, it often happens that taxpayers discover an error occurred in filing a prior year’s return. If an error is discovered, it may … Continue reading Overseas Americans: Fast Facts About Amending a US Income Tax Return →

Tax Planning – Ownership of Foreign Real Property

Investment decisions are difficult nowadays, but I am still getting inquiries from US persons about the US tax effects of owning foreign real property. Tax efficient structuring depends on numerous factors. While an earlier blog post discussed the general concept of what is called a "disregarded entity" and how it is used (and misused) by … Continue reading Tax Planning – Ownership of Foreign Real Property →

Prince Harry (Part I) – Does US Citizenship Wait in the Royal Wings? What about the Impact on the Royal Family?

There are good lessons in today's post for any individual who is considering attaining "US status" - be it by obtaining a green card, US citizenship or through extended physical presence in America. The lessons are explained in detail in a 2-part blog post and will be helpful to Prince Harry who may possibly take … Continue reading Prince Harry (Part I) – Does US Citizenship Wait in the Royal Wings? What about the Impact on the Royal Family? →

Tax Tips for the US Investor in a Foreign Start-Up: Convertible Notes

My earlier blog post, here examined some of the United States income tax consequences that could occur when a taxpayer mistakenly classifies an advance to a foreign corporation as a “loan” but that the Internal Revenue Service (IRS) treats as a stockholding interest (“equity”) in the corporation. Two follow up posts, here and here examined the … Continue reading Tax Tips for the US Investor in a Foreign Start-Up: Convertible Notes →

Foreign Corporate Tax – How Will it Impact the US Taxpayer of a CFC or PFIC?

While the focus of today's post is how the United Arab Emirates (UAE) forthcoming Corporate Tax (CT) may impact US persons who are shareholders in a so-called Controlled Foreign Corporation (CFC) or Passive Foreign Investment Company (PFIC), the analysis applies equally to other jurisdictions which impose tax on the corporate entity. We examine today the … Continue reading Foreign Corporate Tax – How Will it Impact the US Taxpayer of a CFC or PFIC? →

UAE Federal Corporate Tax: How Will it Impact the US Taxpayer? Part II

As discussed in my prior blog post, full details here, on January 31, the United Arab Emirates (UAE) Ministry of Finance announced the introduction of a federal corporate tax (CT) on business, to be implemented in June 2023. The UAE is joining the other Gulf Cooperation Council countries (with exception for Bahrain) that collect tax … Continue reading UAE Federal Corporate Tax: How Will it Impact the US Taxpayer? Part II →

Overview: The Disregarded Entity & Check-the-Box

What Is a Disregarded Entity? How is it Used in US Tax Planning? Certain business entities can be treated as “nonexistent” for federal income tax purposes. That is, from a US tax perspective, they are simply “disregarded” and the entity is ignored by the Internal Revenue Service (IRS). For other purposes, the entity is not disregarded, … Continue reading Overview: The Disregarded Entity & Check-the-Box →

Is IRS Finally Seeing the Light on Foreign Information Returns?

Bloomberg Tax - I invite readers to enjoy my recently published article, copied in full below. Reproduced with permission. Published December 3, 2021. The Bureau of National Affairs, Inc. (800-372-1033) http://www.bloombergindustry.com published in Tax Insights and Commentary News, online here. Various options are available to correct the problem of missing information returns for U.S. … Continue reading Is IRS Finally Seeing the Light on Foreign Information Returns? →