Tag: covered expatriate

Senator Bernie Moreno Introduces Bill To Eliminate Dual Citizenship

On December 1, 2025, Senator Bernie Moreno (R-OH) introduced the Exclusive Citizenship Act of 2025. The bill would prohibit any person from simultaneously holding U.S. citizenship and citizenship of another country. The major provisions include: An effective date 180 days after enactment. The requirement that existing dual citizens would have one year to renounce all … Continue reading Senator Bernie Moreno Introduces Bill To Eliminate Dual Citizenship →

40% Transfer Tax: IRS Final Say On Foreign Gifts, Bequests From “Covered Expatriates”

Seventeen years after Congress enacted IRC Section 2801, the IRS (finally) released final regulations implementing the law on January 10, 2025.  It’s been a long wait. The regulations clarify (to a certain extent) the tax implications for U.S. persons receiving certain gifts and bequests from former U.S. citizens and long-term resident green card holders. At its … Continue reading 40% Transfer Tax: IRS Final Say On Foreign Gifts, Bequests From “Covered Expatriates” →

WEBINAR Expatriation & U.S. Tax Implications: Navigating Green Card (LTR) & Citizenship Relinquishment with IRS Final Section 2801 Transfer Tax Updates

If you are a US citizen or green card holder thinking about keeping or giving up your US status, tax professional, tax advisor, immigration consultant, enrolled agent, certified public accountant, family office, wealth advisor or wealth planner you  should definitely attend this webinar.  If you cannot attend, other options to obtain the webinar are available … Continue reading WEBINAR Expatriation & U.S. Tax Implications: Navigating Green Card (LTR) & Citizenship Relinquishment with IRS Final Section 2801 Transfer Tax Updates →

BREAKING! Final IRC Section 2801 Regs Issued on Foreign Gifts or Bequests …. Buckle Up…. Rough Ride Ahead

IRS literally just finalized the Code Section 2801 regulations on January 10.  These long-awaited final regulations concern gifts and bequests received by a U.S. person from foreign persons who were former U.S. citizens or green card holders who qualified as "long term residents" and were "covered expatriates" at the time of giving up their U.S. … Continue reading BREAKING! Final IRC Section 2801 Regs Issued on Foreign Gifts or Bequests …. Buckle Up…. Rough Ride Ahead →

Bitcoin Jesus Challenges Constitutionality Of Expatriation “Exit Tax”

Roger Ver, an early Bitcoin investor renowned as “Bitcoin Jesus” for his evangelism of cryptocurrency since 2011, now finds himself in a legal maelstrom. Ver, a controversial figure in the blockchain world, was arrested in April 2024 in Spain on U.S. criminal charges stemming from allegations of mail fraud, tax evasion, and filing false tax … Continue reading Bitcoin Jesus Challenges Constitutionality Of Expatriation “Exit Tax” →

BREAKING! Expatriation No Cure: Bitcoin Jesus Indicted & Arrested on Tax Fraud

Roger Ver, an early bitcoin investor (from approximately 2011) also known as “Bitcoin Jesus,” was just arrested in Spain based on US criminal charges. According to the indictment filed February 15, 2024 but recently unsealed, Ver has been charged with mail fraud, tax evasion, and filing false tax returns. Ver was a former US citizen who … Continue reading BREAKING! Expatriation No Cure: Bitcoin Jesus Indicted & Arrested on Tax Fraud →

LIVE WEBINAR: EXPATRIATION – DOS, USCIS Forms and Form 8854 GIVING UP A GREEN CARD (LTR) OR US CITIZENSHIP

Join the webinar on August 23 Tuesday at 12 noon EDT. Register here  Tax pro's:  A new line of business awaits if you are prepared to explain the expatriation process, assist with the various Department of State forms, provide guidance to handle the State Department interview, to approach the written statement of reasons for expatriation … Continue reading LIVE WEBINAR: EXPATRIATION – DOS, USCIS Forms and Form 8854 GIVING UP A GREEN CARD (LTR) OR US CITIZENSHIP →

IRS Slipshod Work and Document Destruction Can Mean Big Problems – Especially for Expatriates

The Treasury Inspector General for Tax Administration (TIGTA) has been documenting some careless work being carried out by the Internal Revenue Service (IRS).  We have the most recent TIGTA report (Number 2022-40-036) of May 4, 2022 reporting that the IRS destroyed 30 million “paper-filed information return documents” without bothering to process them beforehand. This destruction … Continue reading IRS Slipshod Work and Document Destruction Can Mean Big Problems – Especially for Expatriates →

Expatriation and Tax Compliance – IRS Fails to Process the Tax Return

As a tax practitioner I have assisted many taxpayers for decades with expatriation issues (i.e., relinquishing US citizenship or a green card held for at least 8 tax years).  In the best case scenario, the taxpayer can avoid being treated as a "covered expatriate" (CE). Sometimes tax planning, correcting tax returns or submitting delinquent international … Continue reading Expatriation and Tax Compliance – IRS Fails to Process the Tax Return →

Timing Considerations for Expatriation, Tax Compliance and Form 8854

I invite readers to enjoy my article, copied below, recently published by Bloomberg Tax in the Daily Tax Report.  Reproduced with permission. Published January 7, 2022. The Bureau of National Affairs, Inc. (800-372-1033) http://www.bloombergindustry.com It is online here.   My blog post today contains additional input with a link to a podcast on this topic with US … Continue reading Timing Considerations for Expatriation, Tax Compliance and Form 8854 →