Estate Taxes Going Up – Is There Still a Golden Gifting Opportunity?

Janet Yellen, the former Federal Reserve chairperson is now the new US Secretary of  the Treasury.  She has staunchly defended President Biden's plan to reduce the estate-tax exemption amount from the current US$11.5 million to US$3.5 million, as well as to increase the top estate tax rate from 40% to 45%.  In responding to criticism … Continue reading Estate Taxes Going Up – Is There Still a Golden Gifting Opportunity?

Everyone – Including Foreigners… Stay Away from California! 10-Year Wealth Tax Looms for Single Year Stays Over 60 Days

Why should I blog about a possible wealth tax in California? After all, my US tax blog focusses on international tax matters, US persons abroad, and foreign families with any US connections.  Well, for starters, many of my clients are foreign nationals who (prior to COVID-19) enjoy visiting the US, or have specialized medical treatment … Continue reading Everyone – Including Foreigners… Stay Away from California! 10-Year Wealth Tax Looms for Single Year Stays Over 60 Days

US Person Inheriting Assets from a “Foreigner” or Through a Foreign Trust

Many individuals have questions about the US tax consequences of foreign (non-US) assets inherited from a non-US individual who has passed away. They want to know whether US tax reporting is required, or if they must pay US tax on the inheritance. Some ask about the US tax upon a later sale of the inherited … Continue reading US Person Inheriting Assets from a “Foreigner” or Through a Foreign Trust

MERRY CHRISTMAS: FATCA Drops Coal on the Doorstep of Americans Abroad

Merry Christmas to all of my readers and followers who celebrate this special time of year. I hope the joy of the season will follow you into the New Year. Sadly, Christmas won’t be merry for many Americans abroad who are ensnared in the grip of “FATCA,” the notorious “Foreign Account Tax Compliance Act”.  Briefly, … Continue reading MERRY CHRISTMAS: FATCA Drops Coal on the Doorstep of Americans Abroad

IRS Stealth: Delinquent Information Submission Procedure Penalties May Apply Without Considering “Reasonable Cause” Statement

On November 5, the Internal Revenue Service (IRS) made life more difficult for taxpayers who may have missed some foreign information return filings.  The IRS quietly revised one of the four options to correct for missing information returns with respect to a US taxpayer’s interest in any offshore/foreign assets and holdings (e.g., Form 8938, Form … Continue reading IRS Stealth: Delinquent Information Submission Procedure Penalties May Apply Without Considering “Reasonable Cause” Statement

Mr. Biden’s Tax Plans – Serious Pain in Store for those Expatriating, Pain for Americans Abroad…. And Others!

Looking at Mr. Biden’s tax proposals and now faced with his win of the presidency, coupled with Democrat control of the House, Americans abroad are in for a rough time.  This is especially true for anyone considering giving up US citizenship or long term permanent residency (LTR).  Those thinking about expatriation must take immediate action … Continue reading Mr. Biden’s Tax Plans – Serious Pain in Store for those Expatriating, Pain for Americans Abroad…. And Others!

Foreign Trust Forms 3520 and 3520-A Penalties: A Potential Gold Mine for the IRS

The Internal Revenue Service (IRS) is looking for money.  As part of the hunt, it has instituted various “campaigns” (full list here) aimed at areas in which there is greater taxpayer noncompliance that may involve significant tax dollars and penalties. One such campaign involves the failure by a US person to file complex information-reporting tax … Continue reading Foreign Trust Forms 3520 and 3520-A Penalties: A Potential Gold Mine for the IRS

CONFUSED? FinCEN Blows it….FBAR Due Date Now Extended Till October 31 2020

On October 14, the Financial Crimes Enforcement Network (FinCEN) caused a lot of confusion for taxpayers and their advisors concerning the filing due date for foreign (non-US) financial accounts.  An incorrect posting was issued by FinCEN about the 2020 deadline to file Form 114, Report of Foreign Bank and Financial Accounts, commonly known as the … Continue reading CONFUSED? FinCEN Blows it….FBAR Due Date Now Extended Till October 31 2020