Virginia La Torre Jeker, J.D. — US tax matters affecting international clients
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
Giving a significant amount of investment assets to one’s children used to be a popular tax strategy, since it permitted the income earned on the investment to be taxed at the child’s presumably lower tax rate. Congress, in its kind-hearted way enacted the so-called “kiddie tax” in 1986 to prevent parents from abusing this strategy. … Continue reading Your Children, Kiddie Tax and US Tax Reform – Tax, Tax, Tax the Kiddies!
I have written a few blog posts on the thorny side of filing US income tax returns, FBARs and various information returns when one is married to a non-resident alien (NRA) spouse. It may be helpful to read those posts here and here before embarking on this one as the earlier posts set out some … Continue reading Tax Court, IRS Speak with Forked Tongue? Section 6013(g) Election to Treat Foreign Spouse as US “Resident”
Former US citizens or long term permanent residents who are giving up (or previously gave up) their US status, have far more than just the "Exit Tax" to worry about. They must also consider the impact the expatriation will have on their US family members and other intended US beneficiaries. I'm still waiting for more … Continue reading Gifts & Bequests from Former Americans – Beware that Trojan Horse
My earlier blog post gave a head’s up to married couples about jointly owned assets when one spouse is a non-US citizen. Virtually every aspect of the US tax rules are impacted by such joint ownership - income tax, gift tax, estate tax, tax information reporting and FBAR reporting under the Bank Secrecy Act. Today's post provides … Continue reading LOVE SCHMUV! Just K.I.S.S. (Keep It Separate Sweetheart) – US Tax Perils of Joint Ownership
I know many 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
Bloomberg reports that next year, the US may be put on the Organization for Economic Cooperation and Development’s (OECD) “blacklist” of tax haven countries alongside such notables as Guam and Trinidad and Tobago. The move comes as numerous countries continue to question the United States’ adamant refusal to participate in the international information exchange program, … Continue reading Happy New Year – US to be Blacklisted as a Tax Haven?
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…
Virginia - US TAX TALK 