ATTENTION! Married Filing Separately? $5 of Gross Income? Must File US Income Tax Return!

Yes, that did read US$5. Not $50. Not $500……This measly number will heavily impact Americans abroad who are married to non-US spouses. In many instances, the US spouse will file separately and keep the non-US spouse completely out of the US tax picture. This may not always be the best tax strategy but in some … Continue reading ATTENTION! Married Filing Separately? $5 of Gross Income? Must File US Income Tax Return! →

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 →

President Trump – Expatriating?

Well, if my dream last night has anything to do with reality, the world is in for a big shakeup. In my dream, President Trump came to me for US tax advice on expatriation - that is giving up one's US citizenship (or, green card in the case of long term residents). What a bizarre … Continue reading President Trump – Expatriating? →

Cryptocurrency – Criminal Investigations have Commenced!

First, a special thank you to Steve Phillips, a tax & business lawyer in Texas, who alerted me to this recent development. According to an Internal Revenue Service (IRS) special agent, Mr. Chris Hueston, the IRS has now officially begun investigations into tax evasion and other crimes tied to cryptocurrency. The announcement made on November … Continue reading Cryptocurrency – Criminal Investigations have Commenced! →

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 Eye on You! Newest Campaign: Repatriation Tax (IRC Section 965)

Most of my readers have heard about Internal Revenue Code Section 965, and the “deemed repatriation” or “transition tax” introduced by the Tax Cuts and Jobs Act (“TCJA”). My earlier blog post provided significant detail about this tax law provision which was intended to move the US international tax regime into a “territorial system”. In making … Continue reading IRS Eye on You! Newest Campaign: Repatriation Tax (IRC Section 965) →

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! →

Life Gets Complicated When a Foreign Country’s Laws Impact US Tax

Transactions now span the globe with the tap of a key on an I-Phone; families are multi-national, with many living in different parts of the world at different stages in their careers and lives; virtual currency has become official legal tender in at least one country, the United States has de facto imposed enforcement of … Continue reading Life Gets Complicated When a Foreign Country’s Laws Impact US Tax →

IRS Hot on the Trail of Virtual Currency Owners: What IRS Letters to Taxpayers Really Mean

Just last week, the Internal Revenue Service (IRS) reported that it has begun sending letters to taxpayers with virtual currency transactions. The targeted taxpayers are those that potentially failed to report income and pay tax from virtual currency transactions or those who failed to report their transactions properly. Virtual currency transactions involve complex tax issues … Continue reading IRS Hot on the Trail of Virtual Currency Owners: What IRS Letters to Taxpayers Really Mean →