Cryptocurrency (such as Bitcoin) is a type of virtual currency. It is an emerging area, and as such, comes with an enormous amount of uncertainty when it comes to the US tax treatment of transactions involving its use. On October 9, the Internal Revenue Service (IRS) issued Revenue Ruling 2019-24 providing much awaited guidance about … Continue reading IRS Cryptocurrency Update: Taxing Those”Hard Forks” and “Air Drops”
I have written various blog posts covering foreign (i.e., non-US) trusts. Many of them concern US tax filing and reporting requirements with regard to such trusts. My initial post provided a general overview of the troublesome US tax issues surrounding foreign trusts, and my blog post here navigates the tricky waters in determining if a … Continue reading US Tax Filings by Fiduciary of Foreign Trust
The Internal Revenue Service (IRS) has now expanded its compliance campaigns and included “post Offshore Voluntary Disclosure Program compliance” on the list. On July 19th, the IRS through its Large Business and International (LB&I) Division announced six new “compliance campaigns” for taxpayers. Significantly, one of these campaigns targets taxpayers who had entered an Offshore Voluntary Disclosure Program (OVDP) … Continue reading Did you Join OVDP? You’d Better Still be in Tax Compliance!
You may remember my earlier blog post detailing the unenviable case of the wealthy New York Seggerman family which had undisclosed offshore bank accounts inherited from their father. Instead of coming clean and revealing the existence of the accounts to the US Internal Revenue Service (IRS), four of the Seggerman siblings created even more secret … Continue reading A Dangerous Game: Jail Time for Inherited Foreign Accounts
Part I of this blog post examined the importance of the Residency Starting Date (RSD) and how it applied under the Green Card Test. It also pointed out that traps for the unwary can destroy pre-immigration tax planning if one had not correctly nailed down the RSD. Today's post will examine the RSD rules that apply when … Continue reading US Immigrant’s Residency Starting Date – The Devil’s Details – Too Many Days in the USA?
When a foreign individual commences “residency” in the United States for US Income Tax purposes, this date, the Residency Starting Date (RSD), will mark the official date he begins to be taxed on his worldwide income and becomes responsible for various tax information reporting (such as FBAR, Form 5471, Form 8938, to name a few). Commencing on this … Continue reading “Residency Starting Date” – Don’t Leave Home Unless You Understand It!
Today's post is a continuation of a series of blog posts dealing with foreign trusts A general overview of the US tax issues surrounding foreign trusts can be found here. When a US person is involved in any way with a foreign trust extra caution is required. Strict US tax filing responsibilities come into play … Continue reading US Tax Filings by US Grantor of Foreign Trust
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