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

Treaty Tie-Breaker: Oh the Pitfalls Beware!

The United States is unique in its approach to taxing individuals who are US citizens or lawful permanent residents (green card holders).  Such individuals are taxed on worldwide income regardless of where they may reside.  On account of this taxation approach, US citizens and green card holders who live outside of America may be subject … Continue reading Treaty Tie-Breaker: Oh the Pitfalls Beware!

Social Security Benefits Paid to US and Non-US Individuals, Including Those Who Expatriated – How Are They Taxed?

A portion of an individual’s US Social Security retirement, survivors, or disability benefits may be subject to Federal Income tax, regardless if the individual is a US or non-US person. Today’s post looks at the US taxation details on US social security benefits for US and non-US persons.  My earlier blog post here discussed the … Continue reading Social Security Benefits Paid to US and Non-US Individuals, Including Those Who Expatriated – How Are They Taxed?

Breathing American Air – Hazardous to your Wealth? (Part I)

Foreigner asks: “Can I breathe American air without being subject to US tax?” The answer to that question is a big, fat MAYBE.  For starters, it depends how long you were in the US breathing that air.  While the question might sound funny, there is absolute truth in the answer. It amazes me how many … Continue reading Breathing American Air – Hazardous to your Wealth? (Part I)

Mr. FBAR – He Lurks in Every Corner – Katholos Case Expands Meaning of “Financial Interest”

We have another important FBAR case. The case is significant for 2 distinct reasons 1) clarification, and some may say, an ‘expansion’ of the definition of “financial interest” in an account requiring FBAR reporting and 2) a firm demonstration how far the Internal Revenue Service (IRS) will go to assert a civil “willful” FBAR penalty. … Continue reading Mr. FBAR – He Lurks in Every Corner – Katholos Case Expands Meaning of “Financial Interest”

What Can Happen if Your Streamlined Submission Goes Belly-Up? (Part I)

The IRS Streamlined Procedure, whether the Streamlined Foreign Offshore Procedure (SFOP) or the Streamlined Domestic Offshore Procedure (SDOP) of 2014 is still available for taxpayers, but the Internal Revenue Service (IRS) is apparently closely policing those who enter the program. The IRS is now very carefully vetting the cases coming in. A hallmark of the … Continue reading What Can Happen if Your Streamlined Submission Goes Belly-Up? (Part I)

Foreign Loans & Mortgages – Foreigners Residing in US / Expats Returning to US…. Surprise! US Withholding Tax Required on Interest Payments?

Many Americans living abroad purchase properties in their foreign country of residence.  They often accomplish this with financing from a financial institution located in the country where the property was purchased. Later, they may return to the US and continue holding the property and meeting their mortgage payments. Similarly, many non-US citizens purchase properties with … Continue reading Foreign Loans & Mortgages – Foreigners Residing in US / Expats Returning to US…. Surprise! US Withholding Tax Required on Interest Payments?

Tax Planning – Ownership of Foreign Real Property

Investment decisions are difficult nowadays, but I am still getting inquiries from US persons about the US tax effects of owning foreign real property.   Tax efficient structuring depends on numerous factors.  While an earlier blog post discussed the general concept of what is called a "disregarded entity" and how it is used (and misused) by … Continue reading Tax Planning – Ownership of Foreign Real Property

LIVE WEBINAR: EXPATRIATION – DOS, USCIS Forms and Form 8854 GIVING UP A GREEN CARD (LTR) OR US CITIZENSHIP

Join the webinar on August 23 Tuesday at 12 noon EDT. Register here  Tax pro's:  A new line of business awaits if you are prepared to explain the expatriation process, assist with the various Department of State forms, provide guidance to handle the State Department interview, to approach the written statement of reasons for expatriation … Continue reading LIVE WEBINAR: EXPATRIATION – DOS, USCIS Forms and Form 8854 GIVING UP A GREEN CARD (LTR) OR US CITIZENSHIP

Tax Traps for the Generous but Unwary Foreigner with a Child (or other Relative) in the USA

Over my many years of international tax practice, I regularly come across the loving foreign parent (or relative) with a child (or other relation) residing in the United States. The individual may be studying there or living there and pursuing the American dream - starting a business or perhaps buying a home. He or she … Continue reading Tax Traps for the Generous but Unwary Foreigner with a Child (or other Relative) in the USA