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

Part II: Biden Proposal Changes the Taxation Game for Gifts and Inheritances – Americans Abroad Hit Hard

Today's post, Part II, was written with my colleague John Richardson, J.D. Part I of this blog post discussed President Biden's Green Book proposal that would change the tax rules for unrealized capital gains when assets are gifted or passed at death.  To recap, the major thrust of the Green Book proposal is to treat gifts … Continue reading Part II: Biden Proposal Changes the Taxation Game for Gifts and Inheritances – Americans Abroad Hit Hard

“With Liberty and Justice (and Death Taxes) for All” …. Biden Proposal Changes the Taxation Game for Gifts and Inheritances (Part I)

Today's post is in two parts and was written with my colleague John Richardson, J.D. On March 28, President Joe Biden released the FY2023 Budget, also known as the Green Book, available here.   The Green Book is not proposed legislation, but it might be viewed as a kind of reading of the tea leaves showing … Continue reading “With Liberty and Justice (and Death Taxes) for All” …. Biden Proposal Changes the Taxation Game for Gifts and Inheritances (Part I)

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

Caught in the US Tax Trap: Part I How Does a Non-US citizen Become a US “Resident” – Taxed on WORLDWIDE Income?

US “residents” are subject to tax on income derived from all sources. That means they are subject to tax on their worldwide income regardless of the source of that income.  So, for example, dividends earned from a French company are taxable, as is gain on the sale of rental property located in Hong Kong; prize money won … Continue reading Caught in the US Tax Trap: Part I How Does a Non-US citizen Become a US “Resident” – Taxed on WORLDWIDE Income?

Cannot Expatriate! US Consulate in Dubai – Joining Others Worldwide, Closes the Door on Expatriations

An alternative title for this post could be:  "Hasn't the State Department Heard About Zoom?" What’s become of the right to relinquish one’s US citizenship?  It has been thrown a curveball for the past year and a half.   Many US Embassies and Consulates throughout the world are not offering the service.  Those that did (or … Continue reading Cannot Expatriate! US Consulate in Dubai – Joining Others Worldwide, Closes the Door on Expatriations

Senator Sanders – Gift and Estate Tax Reform Proposals Pack a Punch

Anyone out there thinking about estate tax planning, asset protection, making gifts? And, what about those considering expatriation?  I am fielding many more inquiries about expatriation these days.  Well, if you are considering any of these things, my sage advice would be to hurry up.  Major transfer tax law changes look  to be on the … Continue reading Senator Sanders – Gift and Estate Tax Reform Proposals Pack a Punch

Renouncing One’s US Citizenship: More Audits, Virtual Currency, CLN & Travel

COVID-19 restrictions have severely limited services at US embassies and consulates around the world. As a result, renouncing one’s US citizenship has become very difficult, and in many cases, just about impossible at the current time. This gives individuals more time to make sure they have properly planned for expatriation. It's a big step. I … Continue reading Renouncing One’s US Citizenship: More Audits, Virtual Currency, CLN & Travel

Senator Warren’s Proposed Wealth Tax and the 40% Tax Hit on Expatriation

The ‘‘Ultra-Millionaire Tax Act of 2021’’ (the “Act”) was proposed by Democratic Senators Elizabeth Warren and Bernie Sanders on March 1 2021.  Like all other tax proposals I have seen in my over 35+ years of tax practice, once the bee is in the bonnet, legislation will inevitably, inexorably, eventually blossom and flourish.  The Act … Continue reading Senator Warren’s Proposed Wealth Tax and the 40% Tax Hit on Expatriation

Dubai:  Combine your Renunciation with a Vacation  

UPDATE:  Sadly - the US Consulate in Dubai has just informed me that they cannot accept appointments for non-emergency services for non-UAE residents.  Expatriation is considered a non-emergency to them, although I feel sure the individual wishing to expatriate would disagree. I have requested the Consulate to update me if the situation changes.   Welcome … Continue reading Dubai:  Combine your Renunciation with a Vacation