US Tax Filings by US Grantor of Foreign Trust

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

Exit Tax – A Comment on Richardson / Zelinsky Debate on Citizenship Based Taxation

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

It’s About Time! Clearer Tax Guidance for Cryptocurrency…. on the Way

Internal Revenue Service (IRS) commissioner Charles Rettig announced that the IRS plans to issue further guidance on the taxation of cryptocurrency.   Commissioner Retting wrote that “We have been considering these issues and intend to publish guidance addressing these and other issues soon.” Can it be? Is an "IRS rescue" really on the way? Will it … Continue reading It’s About Time! Clearer Tax Guidance for Cryptocurrency…. on the Way

Outrunning (and Outwitting) the IRS Using the Statute of Limitations

With tax returns either filed, in progress for Americans abroad, put on extension... (or late because an extension was not properly filed), now is a good time to look at the various statutes of limitations (SOL) applicable to US tax matters. What is a tax SOL?  Simply, the SOL prescribes the length of time permitted … Continue reading Outrunning (and Outwitting) the IRS Using the Statute of Limitations

Foreign Life Insurance Policy?  Houston, We Have a Problem……

Recently, I blogged about the fact that many US persons living abroad have “foreign” (non-US) life, sickness or accident insurance or a foreign annuity.  A mere handful have any knowledge of the complex US tax rules that may apply to these policies. Buzz words include “passive foreign investment company” (PFIC) exposure, Form 114 Bank Secrecy … Continue reading Foreign Life Insurance Policy?  Houston, We Have a Problem……

Head’s Up! IRS Just Revised EIN Application Procedure & Foreign Taxpayers Will Struggle

Effective as of May 13, taxpayers can no longer request an employer identification number (EIN) unless the "responsible party" named on the application has either a Social Security Number (SSN) or Individual Taxpayer Identification Number  (ITIN). Only governmental entities and the military are exempt from this requirement, and may continue to list non-individual entities as … Continue reading Head’s Up! IRS Just Revised EIN Application Procedure & Foreign Taxpayers Will Struggle

House Blocks IRS Free-File Tax Help: Who Cares!

In early April, the House of Representatives passed a bill that would re-design the Internal Revenue Service (IRS). It had a nifty and promising title, the "Taxpayer First Act of 2019".  Despite its sweet title, part of the bill would prohibit the IRS from providing taxpayers with free tax preparation software. The for-profit tax preparation … Continue reading House Blocks IRS Free-File Tax Help: Who Cares!

The Foreigner and the Taxman: Are You “Married” for US Income Tax Purposes?

Life gets confusing when you’re an American and you’ve married a “foreigner”.  Aside from the cultural and social differences you may encounter, you cannot forget that your US tax situation will now become even more complex.  Many of my tax blog posts explain the thorny side of filing US income tax returns, FBARs and various … Continue reading The Foreigner and the Taxman: Are You “Married” for US Income Tax Purposes?

US Tax Law to American Abroad – “How Do I Hate Thee, Let Me Count the Ways”

Regular readers of my tax blog will not be surprised by the title of this post and the content it hints at delivering. They likely realize by now that the American person abroad is not looked upon favorably by the US tax laws.  The tax laws look at anything “foreign” with a jaundiced eye when … Continue reading US Tax Law to American Abroad – “How Do I Hate Thee, Let Me Count the Ways”

Dubai (and Singapore) – Now IRS Targets for Offshore Investigations

Americans in Dubai / Singapore – If you are not tax compliant, time is really running out.  As reported by Bloomberg on March 8th, an official with the Internal Revenue Service (IRS) Criminal Investigation (CI) unit announced at a Washington DC Federal Bar Association event that CI is considering Dubai and Singapore as its "next … Continue reading Dubai (and Singapore) – Now IRS Targets for Offshore Investigations