Third Party Reporting of Virtual Currency: Who’s Telling the IRS What?

Many of my readers are aware that I have written various blog posts about the US tax issues that surround virtual currency. Some have asked, (perhaps innocently, perhaps not), about so-called “third party reporting” of virtual currency to the Internal Revenue Service (IRS) .  For those who do not know what this means – it’s … Continue reading Third Party Reporting of Virtual Currency: Who’s Telling the IRS What?

REMINDER: Wondering if You (or Your Clients) Need to File an FBAR or Have Been Preparing Them Correctly?

Please spread the word and share this news. I will be making FBAR matters simple in a cost-effective live online training session along with my colleague, Jimmy Sexton, LL.M. a fellow international tax expert. Whether you are preparing your own FBARs or those of your clients, the truth is that some FBAR situations are simple … Continue reading REMINDER: Wondering if You (or Your Clients) Need to File an FBAR or Have Been Preparing Them Correctly?

Want Protection from Criminal Prosecution for Tax Noncompliance? IRS Provides Only One Way

As many will remember, the Offshore Voluntary Disclosure Program (OVDP) closed on September 28 2018 with the promise that the Internal Revenue Service (IRS) would issue new guidance on voluntary disclosures made after that date.  The guidance arrived on November 20 2018 in the form of a 5-page Memorandum (IRS Memorandum LB&I-09-1118-014) (“Memorandum”) by the … Continue reading Want Protection from Criminal Prosecution for Tax Noncompliance? IRS Provides Only One Way

No IRS! The Sky is NOT the Limit….MAJOR FBAR WIN! Penalty is Per FBAR Form, Not Per Account

As all my readers know, the Bank Secrecy Act (BSA) has been requiring US taxpayers to report certain foreign financial accounts and retain detailed records about them.  Failing to file or to properly report all foreign accounts on the notorious “FBAR” (FinCEN Form 114, Report of Foreign Bank and Financial Accounts) can result in very high … Continue reading No IRS! The Sky is NOT the Limit….MAJOR FBAR WIN! Penalty is Per FBAR Form, Not Per Account

Estate Taxes Going Up – Is There Still a Golden Gifting Opportunity?

Janet Yellen, the former Federal Reserve chairperson is now the new US Secretary of  the Treasury.  She has staunchly defended President Biden's plan to reduce the estate-tax exemption amount from the current US$11.5 million to US$3.5 million, as well as to increase the top estate tax rate from 40% to 45%.  In responding to criticism … Continue reading Estate Taxes Going Up – Is There Still a Golden Gifting Opportunity?

Bye-Bye Shell Companies! Beneficial Ownership Reporting Now Required by the USA 

It’s finally here!  We now have a new law mandating creation of a national database of beneficial owners of US businesses (and foreign businesses registered to do business in the US).  It’s been a long time in coming and is being hailed as a huge anti-corruption and anti-money laundering reform .  There have been several … Continue reading Bye-Bye Shell Companies! Beneficial Ownership Reporting Now Required by the USA 

Everyone – Including Foreigners… Stay Away from California! 10-Year Wealth Tax Looms for Single Year Stays Over 60 Days

Why should I blog about a possible wealth tax in California? After all, my US tax blog focusses on international tax matters, US persons abroad, and foreign families with any US connections.  Well, for starters, many of my clients are foreign nationals who (prior to COVID-19) enjoy visiting the US, or have specialized medical treatment … Continue reading Everyone – Including Foreigners… Stay Away from California! 10-Year Wealth Tax Looms for Single Year Stays Over 60 Days

US Person Inheriting Assets from a “Foreigner” or Through a Foreign Trust

Many individuals have questions about the US tax consequences of foreign (non-US) assets inherited from a non-US individual who has passed away. They want to know whether US tax reporting is required, or if they must pay US tax on the inheritance. Some ask about the US tax upon a later sale of the inherited … Continue reading US Person Inheriting Assets from a “Foreigner” or Through a Foreign Trust