Each year, almost 2,000,000 corporations and limited liability companies are being formed under the laws of the various United States. Yet, only a handful of States require information about the beneficial owners of the corporations and limited liability companies formed under their laws. A person forming a corporation or limited liability company within the US … Continue reading No Creation of US Companies or LLCs Without Disclosure! Your Name, Please – Corporate Transparency Act of 2019
Tune in to the amazing debate between John Richardson and Edward Zelinsky, two renowned tax and citizenship professionals, taking place on Friday May 17. Not only is it free, but viewers will receive an unparalleled education about the major issues surrounding US citizenship, its tax consequences for the typical American abroad and Accidental Americans, effects … Continue reading US Citizenship And Worldwide Taxation: Justified?
With tax returns either filed, in progress for Americans abroad, put on extension... (or late because an extension was not properly filed), now is a good time to look at the various statutes of limitations (SOL) applicable to US tax matters. What is a tax SOL? Simply, the SOL prescribes the length of time permitted … Continue reading Outrunning (and Outwitting) the IRS Using the Statute of Limitations
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….
Americans in Dubai / Singapore – If you are not tax compliant, time is really running out. As reported by Bloomberg on March 8th, an official with the Internal Revenue Service (IRS) Criminal Investigation (CI) unit announced at a Washington DC Federal Bar Association event that CI is considering Dubai and Singapore as its "next … Continue reading Dubai (and Singapore) – Now IRS Targets for Offshore Investigations
Crypto currency is on the decline which means that many Americans may have experienced losses with their virtual currency transactions. According to CCN the valuation of the crypto market fell by $4 billion from $130 billion to $126 billion, dropping to the $120 billion region for the first time since mid-February. One must remember, that … Continue reading Bitcoin and Your Taxes: Do You Know What to Do?
I have been keeping readers up to date with the current controversy surrounding imposition of an FBAR penalty for “willful” violations. Here’s an overview of where we are to date. “Willful” Penalty Ceiling: The Cases So Far Last year, two district courts had limited the FBAR “willfulness” penalty to $100,000 because the Department of Treasury did … Continue reading IRS Hits the Jackpot: Another District Court Rejects $100,000 Cap on FBAR Penalty
I work frequently with married couples of mixed nationality, when one spouse is not a US citizen and the other has such citizenship. Without due consideration to the US tax issues, spouses often hold title to bank accounts, brokerage accounts and real property as joint tenants with right of survivorship. Joint ownership often comes about even … Continue reading A Big Mistake – Joint Ownership of Assets With Your Non-US Citizen Spouse
What Every Overseas American Investor Must Know …. Many American investors are confused by sales pitches of expat investment advisors who are most often completely unfamiliar with US tax laws. While it is true that no tax may be payable in the fund's jurisdiction (Isle of Man, Guernsey or the UAE, for instance), significant US … Continue reading US Tax Disaster – Investing in Offshore Funds, Life Policies, Portfolio Bonds
I was hoping that tax reform would have done away with, or at least modified, the troublesome provisions surrounding the PFIC or so-called “Passive Foreign Investment Company”. This was not to be and it prompted me to review the PFIC rules and count the ways they cause trouble! What is a PFIC? A PFIC is … Continue reading PFICs – The Fairytale Definition That Lives Happily Ever After…