Expatriation Numbers Skyrocket! Giving up US Citizenship – Will I be Banned from Re-entering the USA?

Well, the numbers of individuals renouncing US citizenship is apparently reaching epic proportions.  It has been reported that 5,816 Americans gave up their citizenship in the first six months of 2020 and that this represents a 1,210% increase from the prior six months ending December 2019, when only 444 cases were recorded.  Most clients I … Continue reading Expatriation Numbers Skyrocket! Giving up US Citizenship – Will I be Banned from Re-entering the USA?

Surrendering a Green Card at the Border – COVID-19, Stuck Abroad, “Forced” to Surrender Green Card?

Before delving into the nitty gritty, let me start with a disclaimer. I am not an immigration specialist and this post does not address, other than in a very general manner, immigration issues associated with surrendering a green card at the border. Today’s blog post examines the US tax issues that surround relinquishing the green … Continue reading Surrendering a Green Card at the Border – COVID-19, Stuck Abroad, “Forced” to Surrender Green Card?

Expatriated? But Failed to File Form 8854?  IRS Provides a Fix!

2020 looks promising in more ways than one. First, on a professional level I was delighted and proud to be named, for the 4th year running, to Forbes Top 100 Must Follow Tax Twitter Accounts for 2020. Please do encourage your friends and colleagues to follow me on Twitter and to subscribe to my US … Continue reading Expatriated? But Failed to File Form 8854?  IRS Provides a Fix!

IRS “Relief Procedures for Certain Former Citizens” – Hey! What About Green Card Holders?

In September 2019, the Internal Revenue Service (IRS) announced new Relief Procedures for Certain Former Citizens that will enable certain individuals who relinquished (or are relinquishing) 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; nor will … Continue reading IRS “Relief Procedures for Certain Former Citizens” – Hey! What About Green Card Holders?

President Trump – Expatriating?

Well, if my dream last night has anything to do with reality, the world is in for a big shakeup.  In my dream, President Trump came to me for US tax advice on expatriation - that is giving up one's US citizenship (or, green card in the case of long term residents). What a bizarre … Continue reading President Trump – Expatriating?

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!

Have you Expatriated or Thinking of Expatriating? IRS Now Looking Closely

On July 19th, the Internal Revenue Service (IRS) through its Large Business and International (LB&I) Division announced six new “compliance campaigns” for taxpayers. Significantly, one of these campaigns targets “expatriation”, and apparently reaches back to those who “expatriated” on or after June 17, 2008.  The campaign will be looking at “expatriates” – US citizens who … Continue reading Have you Expatriated or Thinking of Expatriating? IRS Now Looking Closely

Expatriation: Deferring Payment of the Exit Tax

I recently blogged about the debate between Prof. Edward Zelinsky and John Richardson as it pertained to the Exit Tax imposed on so-called "covered expatriates".  This was in the broader context of the US income taxation model which is based on one's "citizenship" rather than one's residence. The thrust of my earlier blog post concerned … Continue reading Expatriation: Deferring Payment of the Exit Tax

Exit Tax – A Comment on Richardson / Zelinsky Debate on Citizenship Based Taxation

Recently, a debate took place on the merits of the United States' income tax regime which is based on "citizenship".  This lively debate was between the esteemed John Richardson (a US and Canadian attorney) and Professor Edward Zelinsky (a tax scholar and professor at Cardozo Law School in New York City).  You can watch the … Continue reading Exit Tax – A Comment on Richardson / Zelinsky Debate on Citizenship Based Taxation

Do You Have Foreign Life, Sickness, or Casualty Insurance? A Foreign Annuity Contract? Excise Tax / FBAR / Form 8938….

Many US persons living abroad have foreign life, sickness or accident insurance or a foreign annuity. Yet, only a handful have any knowledge of the US Foreign Insurance Excise Tax provisions affecting these policies.  Foreign asset information reporting may also apply.  Here's what you need to know! Foreign Life Insurance Generally, an excise tax of … Continue reading Do You Have Foreign Life, Sickness, or Casualty Insurance? A Foreign Annuity Contract? Excise Tax / FBAR / Form 8938….