40% Transfer Tax: IRS Final Say On Foreign Gifts, Bequests From “Covered Expatriates”

Seventeen years after Congress enacted IRC Section 2801, the IRS (finally) released final regulations implementing the law on January 10, 2025. It’s been a long wait. The regulations clarify (to a certain extent) the tax implications for U.S. persons receiving certain gifts and bequests from former U.S. citizens and long-term resident green card holders. At its … Continue reading 40% Transfer Tax: IRS Final Say On Foreign Gifts, Bequests From “Covered Expatriates” →

Offshore Tax Evasion: U.S. Clients Of Trident Trust Target Of IRS John Doe Summons

The Department of Justice and the Internal Revenue Service have recently reaffirmed their strong commitment to pursuing offshore tax evasion through the use of powerful investigative tools. One such tool is the IRS John Doe Summons. On Dec. 23, 2024, the United States District Court for the Southern District of New York granted the IRS authority … Continue reading Offshore Tax Evasion: U.S. Clients Of Trident Trust Target Of IRS John Doe Summons →

IRS Tax Records, Foreign Assets: When (And What) To Keep Or Toss

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 →

FATCA Statute of Limitations: IRS’ 2018 Assessment Grabs Tax & Penalties Back to 2003

In Fairbank v. Commissioner, T.C. Memo. 2023-19, Dkt. No. 13400-18 (February 23, 2023) the Internal Revenue Service (IRS) issued a notice of deficiency in April 2018 for taxable years 2003, 2004, 2005, 2006, 2007, 2008, 2009, and 2011. The taxpayers argued the IRS could not go back to these prior years, challenging the assessments on … Continue reading FATCA Statute of Limitations: IRS’ 2018 Assessment Grabs Tax & Penalties Back to 2003 →

Am I Being Cynical? Serious Problems Acknowledged -Too Little, Too Late for Taxpayers Outside the US

The Taxpayer Advocate Service (TAS) recently released its 2022 report to Congress. In one portion of the Report (listed in “Most Serious Problems Encountered by Taxpayers” #10 OVERSEAS TAXPAYERS: Taxpayers Outside of the United States Face Significant Barriers to Meeting Their U.S. Tax Obligations) TAS provided a succinct review of the problems faced by American … Continue reading Am I Being Cynical? Serious Problems Acknowledged -Too Little, Too Late for Taxpayers Outside the US →

Overseas Americans: Fast Facts About Amending a US Income Tax Return

Soon enough thoughts will turn to preparing US tax returns for 2022. Thorough preparation should at least include a review of the tax return filed for the prior tax year. In doing this, it often happens that taxpayers discover an error occurred in filing a prior year’s return. If an error is discovered, it may … Continue reading Overseas Americans: Fast Facts About Amending a US Income Tax Return →

US Tax – Safeguarding Finances of the Elderly, Stateside and Abroad

My latest article is copied below in full, as published by Bloomberg Tax, December 9, 2022 in Tax Insights, reproduced with permission, link here.The Bureau of National Affairs, Inc. (800-372-1033) http://www.bloombergindustry.com The growing trend of email and phone scammers, combined with the potential for diminished cognitive abilities due to aging, can imperil elderly people’s financial … Continue reading US Tax – Safeguarding Finances of the Elderly, Stateside and Abroad →

Prince Harry (Part I) – Does US Citizenship Wait in the Royal Wings? What about the Impact on the Royal Family?

There are good lessons in today's post for any individual who is considering attaining "US status" - be it by obtaining a green card, US citizenship or through extended physical presence in America. The lessons are explained in detail in a 2-part blog post and will be helpful to Prince Harry who may possibly take … Continue reading Prince Harry (Part I) – Does US Citizenship Wait in the Royal Wings? What about the Impact on the Royal Family? →

Is the IRS Being Reasonable when it comes to “Reasonable Cause”?

My recent blog post discussed how I approach “streamlined procedure” filings for taxpayers with unreported income, for example, from offshore assets or accounts. Often, the tax noncompliance for such cases involves unfiled international information returns as well. As discussed in the blog post, I draft the required statement of non-willfulness in such a manner that … Continue reading Is the IRS Being Reasonable when it comes to “Reasonable Cause”? →

“With Liberty and Justice (and Death Taxes) for All” …. Biden Proposal Changes the Taxation Game for Gifts and Inheritances (Part I)

Today's post is in two parts and was written with my colleague John Richardson, J.D. On March 28, President Joe Biden released the FY2023 Budget, also known as the Green Book, available here. The Green Book is not proposed legislation, but it might be viewed as a kind of reading of the tea leaves showing … Continue reading “With Liberty and Justice (and Death Taxes) for All” …. Biden Proposal Changes the Taxation Game for Gifts and Inheritances (Part I) →