US Tax Issues Abound: A Global Look at Protecting Vulnerable Persons from Financial Fraud (The Case of the Wicked Stepdaughter)

On Wednesday I presented a webinar for the Financial Planning Association’s July International & Cross-Border Planning Knowledge Circle. My webinar highlighted numerous US tax issues when safeguarding the finances of the elderly (or other vulnerable individuals), whether Stateside or overseas. You can listen to the entire webinar here. The Case of the Wicked Stepdaughter A … Continue reading US Tax Issues Abound: A Global Look at Protecting Vulnerable Persons from Financial Fraud (The Case of the Wicked Stepdaughter) →

Malta Retirement Plans – The Jig is Really Up!

Things are looking worse and worse for Americans who invested in Malta personal retirement plans. Not only has the Internal Revenue Service (IRS) listed them twice on its Dirty Dozen tax scams list, it has now proposed rules that will require taxpayers and material advisers to specially put the IRS on notice about their use. … Continue reading Malta Retirement Plans – The Jig is Really Up! →

FATCA Reporting of Compensatory Foreign Stock Option on Form 8938

My earlier blog post covered some US tax issues faced by the individual granted options on foreign company stock by his non-US employer. When it comes to foreign information return reporting, the grant of options to an employee on foreign stock can get confusing. Is an option granted to an employee with respect to foreign … Continue reading FATCA Reporting of Compensatory Foreign Stock Option on Form 8938 →

FATCA Statute of Limitations: IRS’ 2018 Assessment Grabs Tax & Penalties Back to 2003

In Fairbank v. Commissioner, T.C. Memo. 2023-19, Dkt. No. 13400-18 (February 23, 2023) the Internal Revenue Service (IRS) issued a notice of deficiency in April 2018 for taxable years 2003, 2004, 2005, 2006, 2007, 2008, 2009, and 2011. The taxpayers argued the IRS could not go back to these prior years, challenging the assessments on … Continue reading FATCA Statute of Limitations: IRS’ 2018 Assessment Grabs Tax & Penalties Back to 2003 →

Tax Statutes of Limitation – Run Fast, IRS is Right Behind You

With tax season in full swing, now is a good time to review the various civil statutes of limitations (SOL) rules that apply to US tax matters. Perfect timing to review because we also have a Tax Court case from last month showing how harsh the consequences of the SOL can be if a taxpayer … Continue reading Tax Statutes of Limitation – Run Fast, IRS is Right Behind You →

Free for You: My Cross-Border Tax Presentation for the Financial Planning Association

On March 15, I was delighted to present cross-border tax topics of interest for the Financial Planning Association (FPA). FPA is a well-known membership organization for certified financial planner professionals and those engaged in the financial planning process. It provides its members with practice support, learning, advocacy, and networking. As a tax professional, with 40 … Continue reading Free for You: My Cross-Border Tax Presentation for the Financial Planning Association →

The Perfect Storm – US Tax, Community Property & the Mobile International Couple

Last week I blogged about how the US tax system can create serious tax problems for the international couple when one is a US person and the other is not. In order to keep things simple, it is often advised that the couple hold assets separately to avoid nasty US tax complications. However, in some … Continue reading The Perfect Storm – US Tax, Community Property & the Mobile International Couple →

Treaty Tie-Breaker is an FBAR Escape Hatch, Says the Court!

It has been the position of the Internal Revenue Service (IRS) that a “Report of Foreign Bank and Financial Accounts” (Form 114), commonly called the “FBAR”, must still be filed to report any foreign accounts, despite a green card holder’s treaty tie-breaker claim. It came as a big surprise to me that the United States … Continue reading Treaty Tie-Breaker is an FBAR Escape Hatch, Says the Court! →

BREAKING! US Supreme Court — FBAR “Nonwillful” Penalty is Per Form and NOT Per Account

What we have all been waiting for! Bittner v. United States was just decided hours ago by the United States Supreme Court! An amazing taxpayer win. It is late here in the Middle East, so I provide only the information you need to know! You can read the full case here. The Bank Secrecy Act … Continue reading BREAKING! US Supreme Court — FBAR “Nonwillful” Penalty is Per Form and NOT Per Account →

FBAR Penalties – US v. Molyneux and the Big Fat Money Grab

The United States Supreme Court has just set the stage for sky high FBAR penalties. How did this happen? Let's take a look - The case of United States v. Toth, No. 21-1009 (1st Cir. 2022) was on appeal to the US Supreme Court. The focus of the appeal was that the FBAR penalty was … Continue reading FBAR Penalties – US v. Molyneux and the Big Fat Money Grab →