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.
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)
The Internal Revenue Service (IRS) and the Financial Crimes Enforcement Network (FinCEN) will jointly examine application of foreign account reporting requirements to virtual currency held in an offshore account under the Bank Secrecy Act (the notorious FBAR, Form 114). Two important points about FBAR duties for foreign accounts holding virtual currency were made in a … Continue reading FinCEN: No FBAR Reporting for Virtual Currency in an Offshore Account
“Foreign” pension or similar plans are a very common feature in the lives of US expats residing and working abroad. As used here, the word “pension” is only a general term. While pensions in the United States often refer to defined benefit retirement plans, my use in today’s blog post refers to a pension as … Continue reading Oh No! I Have a “Foreign” Pension or Employee Savings Plan and Uncle Sam is Killing Me (Part I)
2020 looks promising in more ways than one. First, on a professional level I was delighted and proud to be named, for the 4th year running, to Forbes Top 100 Must Follow Tax Twitter Accounts for 2020. Please do encourage your friends and colleagues to follow me on Twitter and to subscribe to my US … Continue reading Expatriated? But Failed to File Form 8854? IRS Provides a Fix!
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!
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
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?
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!
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