Virginia La Torre Jeker, J.D. — US tax matters affecting international clients
Most people have heard of it, but not many truly understand it. I will hear a foreign individual proudly state he cannot be taxed by the US since he has no income from US sources and has not spent 183 days or more in the US in any calendar year. Therein lies the “misunderstanding” and … Continue reading Too Many Days in America? The “Closer Connection Exception” May Save the Day (& the Tax Hit)
Holidays are soon upon us, and many people will be making gifts to family and friends. It is very common to make gifts of cash – typically sending funds from a bank account to the recipient’s account. When gifts are made by foreign persons to US persons, there are many US tax traps for both … Continue reading Tis the Season! Giving / Getting Gifts from a Foreign Entity?
If you or your clients are really (really) wealthy (more than $100 million in annual income or more than $1 billion in assets) and thinking about expatriation (relinquishing US citizenship or a green card as a long-term resident), the time is now. Even if not super wealthy, the newly proposed Billionaires Income Tax should serve … Continue reading Billionaires Income Tax On the Way & Covered Expats are Hit Hardest of All
Revenue Procedure 2023-34 was released by the IRS on November 9, 2023. It provides full details about the annual inflation adjustments that are important in the world of US tax and impact over 60 tax provisions in the Internal Revenue Code ("Code"), including tax rate schedules and many other tax changes. Tax pro’s have been … Continue reading Tax Planning – “Foreign/International” Annual Inflation Adjustments Coming in 2024
On Wednesday I presented a webinar for the Financial Planning Association’s July International & Cross-Border Planning Knowledge Circle. My webinar highlighted numerous US tax issues when safeguarding the finances of the elderly (or other vulnerable individuals), whether Stateside or overseas. You can listen to the entire webinar here. The Case of the Wicked Stepdaughter A … Continue reading US Tax Issues Abound: A Global Look at Protecting Vulnerable Persons from Financial Fraud (The Case of the Wicked Stepdaughter)
Things are looking worse and worse for Americans who invested in Malta personal retirement plans. Not only has the Internal Revenue Service (IRS) listed them twice on its Dirty Dozen tax scams list, it has now proposed rules that will require taxpayers and material advisers to specially put the IRS on notice about their use. … Continue reading Malta Retirement Plans – The Jig is Really Up!
My earlier blog post covered some US tax issues faced by the individual granted options on foreign company stock by his non-US employer. When it comes to foreign information return reporting, the grant of options to an employee on foreign stock can get confusing. Is an option granted to an employee with respect to foreign … Continue reading FATCA Reporting of Compensatory Foreign Stock Option on Form 8938
With more and more expatriates working outside the United States, many tax questions arise when an employee is given options to buy stock in the foreign company employer. Stock options are increasingly becoming an important element of the international executive’s compensation package. There are wonderful opportunities to be had with stock options, but there are … Continue reading US Tax Treatment: Stock Options from Your Foreign Employer
The Internal Revenue Service (IRS) was sucker-punched by the Tax Court on April 3, 2023 in the case of Farhy v. Commissioner, 160 T.C. No. 6 (2023). In that case, the Tax Court held that the IRS does not have the authority to assess and collect penalties asserted under Internal Revenue Code Section 6038(b), in the … Continue reading Big Win for Taxpayers with Foreign Assets: IRS Lacks Authority to Assess & Collect Penalties for Failure to File Foreign Information Returns
We have had a taxpayer win in the foreign information reporting arena! I provide a summary of the case of Mr. Krzysztof Wrzesinski below. For readers who wish more, the taxpayer’s complaint is here. Background of the Wrzesinski Case Mr. Wrzesinski (“Taxpayer” or “T”) was a native of Poland who immigrated to the United States … Continue reading Taxpayer Wins! Foreign Gift Not Reported: DOJ Concedes he had “Reasonable Cause”
Virginia - US TAX TALK 