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
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)
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
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!
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
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
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
When a foreign individual commences “residency” in the United States for US Income Tax purposes, this date, the Residency Starting Date (RSD), will mark the official date he begins to be taxed on his worldwide income and becomes responsible for various tax information reporting (such as FBAR, Form 5471, Form 8938, to name a few). Commencing on this … Continue reading “Residency Starting Date” – Don’t Leave Home Unless You Understand It!
Today's post is a continuation of a series of blog posts dealing with foreign trusts A general overview of the US tax issues surrounding foreign trusts can be found here. When a US person is involved in any way with a foreign trust extra caution is required. Strict US tax filing responsibilities come into play … Continue reading US Tax Filings by US Grantor of Foreign Trust
Recently, a debate took place on the merits of the United States' income tax regime which is based on "citizenship". This lively debate was between the esteemed John Richardson (a US and Canadian attorney) and Professor Edward Zelinsky (a tax scholar and professor at Cardozo Law School in New York City). You can watch the … Continue reading Exit Tax – A Comment on Richardson / Zelinsky Debate on Citizenship Based Taxation