Virginia La Torre Jeker, J.D. — US tax matters affecting international clients
It is usually very quick and easy to set up a foreign corporation - say, one in Belize or in the Cayman Islands. What is not so easy is working one's way through the quagmire of required Internal Revenue Service (IRS) reporting and US tax obligations simply because you are a US person owning shares … Continue reading Quicksand! US Owners of Foreign Corporations
One Country, Two Citizenships: John Richardson Interviews Virginia La Torre Jeker. Most people don’t know that the US has two kinds of citizenship – “Immigration” citizenship and “Tax” citizenship. Tax citizenship, the monkey on your back, is hard to shake off! Watch the interview, here. All the US tax information you need, every week … Continue reading USA: One Country, Two Citizenships
My blog post containing tax-saving tips for the filing of a US income tax return when one is married to a non-resident alien spouse is here. It will be helpful to read that post before embarking on this one as it sets out the basics and provides the income tax rates and brackets for the 2018 … Continue reading Married to A Non-US Spouse? Use of “Resident” Election, Filing FBAR and Form 8938
A US citizen or US tax resident (for example, a green card holder) who is married to a non-American when the couple lives abroad should consider certain US tax filing issues and strategies. US Tax Treatment of the Non-US Spouse When the non-US citizen spouse has obtained a green card or is otherwise treated as a … Continue reading Married to A Non-US Spouse? Tax Saving Tips For the US Income Tax Return
Sometimes an individual will come to me with a pesky problem – they have filed a tax return, but it fraudulently omitted income. Typically, a lot of income. Typically, from foreign sources. Always, in hopes the omission will go unnoticed by the IRS. The thinking is along the lines that since the omission involves foreign … Continue reading Too Little, Too Late: Fixing the Fraudulent Tax Return
Very few US Estate tax returns are actually filed by the estates of nonresident alien individuals. Statistics indicate that the amount of Estate Tax earned by the US Government on such returns is quite small. The cost of structuring to avoid the tax is probably of far greater magnitude than what is collected by the US … Continue reading All the Fun Rules — US Estate Tax for Nonresident Alien Individuals
US persons (e.g., US citizens, US green card holders) must make an information report to the IRS when making certain transfers to foreign (non-US) corporations. Specifically, when a US person transfers (or is treated under the tax rules as having transferred) property to a foreign corporation in certain “non-recognition” transactions (e.g., a contribution of capital … Continue reading Transfer of Property or Cash to a Foreign Corporation? FILING OF FORM 926
Henry Seggerman has first-hand experience with this type of situation. Without hesitation, my guess is that he’ll tell you to get the Estate into an IRS Voluntary Disclosure Program (“VDP”). Here is the tale of the unenviable case of the Seggermans! Henry was the son of a prominent New York businessman who passed away. Henry was … Continue reading What if Someone Dies Owning an Undeclared Foreign Financial Account? What Should The Executor & Heirs Do?
Learn about the interplay between foreign corporations and eligibility for lower tax rates available only for "qualified dividends". It's a complicated topic and all of the posts in the series should be read in order to understand the ramifications. Part I, Part II and below, Part III. Unsurprisingly, many US owners of corporations that are … Continue reading Dividends from Foreign Corporations Part III – “Controlled Foreign Corporations”
Learn about the interplay between foreign corporations and eligibility for lower tax rates available only for "qualified dividends". It's a complicated topic and all of the posts in the series should be read in order to understand the ramifications. Access links here Part I, Part II (which appears below) and Part III. Unsurprisingly, many US owners of corporations … Continue reading Dividends from Foreign Corporations Part II – “Controlled Foreign Corporations”
Virginia - US TAX TALK 