Tag: Expatriation

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 →

Escaping the USA, Exit Tax and Transfer Tax Regimes: Using the “Dual National” Exception

Join me today in a live webinar: Everything you need to know about giving up a green card or US citizenship  - 2 CPE credits. Register here. The economy is not looking good with the stock market dropping sharply, with tech companies being hit most dramatically, dropping by about 40%.  Crypto markets are also in … Continue reading Escaping the USA, Exit Tax and Transfer Tax Regimes: Using the “Dual National” Exception →

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 →