Virginia La Torre Jeker, J.D. — US tax matters affecting international clients
When love crosses borders, tax complexity often follows. I know this from first-hand experience having married a Swiss national almost 4 decades ago. When U.S. citizens marry foreign nationals who are not U.S. tax residents a host of U.S. tax rules can upend marital bliss by causing tax compliance complexities that are often difficult to … Continue reading A Complicated U.S. Tax Life: Foreign Spouses And Community Property
Lenders who advance cash to corporations often do so with a clear expectation: the company will repay the principal and will pay interest, and the borrower will report interest income. Yet for U.S. taxpayers the moment of truth comes much later, sometimes years after the money has left the bank—when the IRS, or a court, … Continue reading Corporate ‘Loans’: The Debt v. Equity IRS Challenge And Tax Nightmares
Some exciting news. I am presenting a webinar on Monday, July 28 2025. 2 IRS CPE credits. 12:00 PM ET | 11:00 AM CT | 09:00 AM PT 90 MINUTES Hope to see you there. Please share with your colleagues and friends who may have interest in this topic. REGISTER AT THE LINK: https://educatorprime.com/product/remote-work-global-teams-u-s-tax-what-every-cpa-and-ea-needs-to-know WEBINAR … Continue reading WEBINAR – Remote Work, Global Teams & U.S. Tax: What Every CPA and EA Needs to Know
The U.S. House of Representatives just passed H.R. 1, the “One Big Beautiful Bill Act” by a narrow margin, with the vote being 215 to 214. Foreign persons (including foreign governments) considering inbound investments should pay close watch as this develops. The OBBBA has many tax provisions, but one (Section 112029 of the OBBBA) would … Continue reading One Big Beautiful Revenge Tax: Hits Foreigners From “Unfair Tax” Jurisdictions
Many people face the dilemma of what to do with old tax returns and supporting paperwork, often wondering when it’s safe to discard them. However, determining the right time can be tricky, especially for taxpayers with foreign assets. Those with overseas financial interests must pay particular attention for several reasons, including expanded statutes of limitation … Continue reading IRS Tax Records, Foreign Assets: When (And What) To Keep Or Toss
The Department of Justice and the IRS are champing at the bit to nail former defense contractor, Douglas Edelman, and his French wife Delphine Le Dain. They were charged with schemes to defraud the United States and evade taxes on more than $350 million using a complicated nominee arrangement. "Oh Mr. Taxman, I know it looks like my … Continue reading Mr. Taxman @IRS: Looks Like My Money, But It Really Isn’t…
I have written earlier on the case of Farhy v. Commissioner. There 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 Farhy case, the assessed penalties were imposed for failure to file Form 5471, the IRS form required … Continue reading Another Breaking! Farhy Overruled – A Big Loss for Overseas Americans
In a holding by the US Tax Court on April 8, 2024, the case of Raju J. Mukhi v. Commissioner of Internal Revenue brought into sharp focus the principle of stare decisis and its implications for tax law. The Tax Court rejected the IRS’ assessment of penalties under Section 6038(b), for failure to file Form … Continue reading Taxpayer Wins Again on 5471 Penalty – IRS Cannot Assess
In a globalized economy, foreign investment plays a pivotal role in driving economic growth and innovation. For years, the United States has been a beacon for international investors seeking lucrative opportunities. However, concerns surrounding transparency and accountability have often loomed large, creating barriers for foreign investors navigating the complex landscape of American business. Enter the … Continue reading Transparency Triumph? How the Corporate Transparency Act Impacts Foreign Investors in the USA
My earlier blog post discussed National Small Business United v. Yellen, No. 5:22-cv-01448 (N.D. Ala.), the Northern District Court of Alabama decision that enjoined all relevant US government agencies from enforcing the Corporate Transparency Act (CTA). That post raised the issue: exactly who is entitled to the benefits of this injunction? Well, let's look carefully … Continue reading Corporate Transparency Act – Unconstitutional, But Keep Reporting!
Virginia - US TAX TALK 