IRS Wants Help on Cryptocurrency Audits – Seeks Private Crypto Gurus

We know that the Internal Revenue Service (IRS) has been investigating tax evasion and other crimes tied to cryptocurrency. The agency has been hard at work for some time in scrutinizing crypto and for the past two years, it has been in the process of developing and executing investigation techniques to enforce cryptocurrency compliance. Along … Continue reading IRS Wants Help on Cryptocurrency Audits – Seeks Private Crypto Gurus →

Getting a Green Card – Is it Really Worth It?

I recently spoke on the US tax issues faced by the holder of the green card. To be or not to be such a holder? The podcasts (links below) may help you decide. The podcasts were made with John Richardson, a US and Canadian attorney. John, who is based in Canada, has seen his fair … Continue reading Getting a Green Card – Is it Really Worth It? →

WAKE UP CALL: Form BE-10

The Bureau of Economic Affairs (BEA) is a division of the US Department of Commerce. The BEA administers the so-called Form BE-10 survey, which is an intensive information gathering tool of the US government. The BE-10 is used to collect information on how US persons are investing abroad and on foreign investment in the US. … Continue reading WAKE UP CALL: Form BE-10 →

The Flexible “Foundation” – It’s Becoming a Thing!

Recently I was the guest speaker on Jimmy Sexton’s podcast discussing all things related to an entity called a “foundation”. A foundation is a creature of a country’s statutory law, but foundations are not well understood in common law jurisdictions, such as the United States. In the podcast, we looked at the difference between civil … Continue reading The Flexible “Foundation” – It’s Becoming a Thing! →

Warning: Marriage to a ‘Foreigner’ May Be Hazardous to Your Tax Health

Recently, I am seeing more and more married couples of dual nationality (with one US individual partner) struggling with the US tax issues wrought by such a "mixed marriage". Some are same sex couples married under the laws of a foreign (non-US) jurisdiction. Believe it or not, marriages taking place in a foreign country (whether … Continue reading Warning: Marriage to a ‘Foreigner’ May Be Hazardous to Your Tax Health →

Surrendering a Green Card at the Border – COVID-19, Stuck Abroad, “Forced” to Surrender Green Card?

Before delving into the nitty gritty, let me start with a disclaimer. I am not an immigration specialist and this post does not address, other than in a very general manner, immigration issues associated with surrendering a green card at the border. Today’s blog post examines the US tax issues that surround relinquishing the green … Continue reading Surrendering a Green Card at the Border – COVID-19, Stuck Abroad, “Forced” to Surrender Green Card? →

Handle With Care: How Sharia Law and U.S. Tax Law Affect the Foundations Regime in the United Arab Emirates

Proud to announce publication of my article Handle With Care: How Sharia Law and U.S. Tax Law Affect the Foundations Regime in the United Arab Emirates in Tax Notes International (TNI) Vol. 98 No. 5 May 4, 2020. Available at no cost on SSRN. The article discusses the US tax treatment of the newest "foundations" … Continue reading Handle With Care: How Sharia Law and U.S. Tax Law Affect the Foundations Regime in the United Arab Emirates →

Timing is Everything: The Market is in Freefall Creating a Window of Tax Opportunity – Make Your Gifts Now

The US gift tax is a tax imposed on the transfer of property by way of gift. The giver of the gift (the donor) is the party who must pay the tax. Generally, any transfer to an individual without receiving something of equal value in return (measured in money or money's worth) is treated as … Continue reading Timing is Everything: The Market is in Freefall Creating a Window of Tax Opportunity – Make Your Gifts Now →

IRS’ Crypto Guidance – No, You Cannot Rely On It.

Cyptocurrency (such as Bitcoin) is a type of virtual currency. This is an emerging area and consequently transactions involving use of crypto come with an enormous amount of US tax uncertainty. The Internal Revenue Service (IRS) has taken a keen interest in virtual currency since its use provides a way for taxpayers to avoid tax … Continue reading IRS’ Crypto Guidance – No, You Cannot Rely On It. →

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

Part I of this blog post introduced the topic of the "foreign" pension or employee workplace savings plan, and examined in some detail how these plans are becoming more and more popular in the United Arab Emirates. The plans, however, give US expatriate employees some serious US tax headaches. Today's post focusses on these thorny … Continue reading Oh No! I Have a “Foreign” Pension or Employee Savings Plan and Uncle Sam is Killing Me (Part II) →