FinCEN: No FBAR Reporting for Virtual Currency in an Offshore Account

The Internal Revenue Service (IRS) and the Financial Crimes Enforcement Network (FinCEN) will jointly examine application  of foreign account reporting requirements to virtual currency held in an offshore account under the Bank Secrecy Act (the notorious FBAR, Form 114).  Two important points about FBAR duties for foreign accounts holding virtual currency  were made in a … Continue reading FinCEN: No FBAR Reporting for Virtual Currency in an Offshore Account

Oh No! I Have a “Foreign” Pension or Employee Savings Plan and Uncle Sam is Killing Me (Part I)

“Foreign” pension or similar plans are a very common feature in the lives of US expats residing and working abroad. As used here, the word “pension” is only a general term. While pensions in the United States often refer to defined benefit retirement plans, my use in today’s blog post refers to a pension as … Continue reading Oh No! I Have a “Foreign” Pension or Employee Savings Plan and Uncle Sam is Killing Me (Part I)

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?

Dangerous Liaisons: Foreign Assets and the US Nominee

We’ve known for some time that the Internal Revenue Service (IRS) has been mining heaps of data provided to it by financial institutions that were the subject of non-prosecution agreements, as well as examining treasure troves of financial information from various leaks (think “Panama Papers”) looking not only for tax dollars, interest and penalties but … Continue reading Dangerous Liaisons: Foreign Assets and the US Nominee

US Beneficiary of Foreign Trust: Understanding US Tax Filings

I have written a series of blog posts about foreign (i.e., non-US) trusts and the US tax issues associated with them including the US tax filing and reporting requirements for each of the different players in the foreign trust scenario (creator or "grantor"/"settlor" of the trust), the trustee; and today, the US beneficiary. One of … Continue reading US Beneficiary of Foreign Trust: Understanding US Tax Filings

IRS Cryptocurrency Update:  Taxing Those”Hard Forks” and “Air Drops”

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”

US Tax Filings by Fiduciary of Foreign Trust

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

Did you Join OVDP? You’d Better Still be in Tax Compliance!

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!

A Dangerous Game: Jail Time for Inherited Foreign Accounts

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

US Immigrant’s Residency Starting Date – The Devil’s Details – Too Many Days in the USA?

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?