Expatriation and Tax Compliance – IRS Fails to Process the Tax Return

As a tax practitioner I have assisted many taxpayers for decades with expatriation issues (i.e., relinquishing US citizenship or a green card held for at least 8 tax years).  In the best case scenario, the taxpayer can avoid being treated as a "covered expatriate" (CE). Sometimes tax planning, correcting tax returns or submitting delinquent international … Continue reading Expatriation and Tax Compliance – IRS Fails to Process the Tax Return

Part II: Biden Proposal Changes the Taxation Game for Gifts and Inheritances – Americans Abroad Hit Hard

Today's post, Part II, was written with my colleague John Richardson, J.D. Part I of this blog post discussed President Biden's Green Book proposal that would change the tax rules for unrealized capital gains when assets are gifted or passed at death.  To recap, the major thrust of the Green Book proposal is to treat gifts … Continue reading Part II: Biden Proposal Changes the Taxation Game for Gifts and Inheritances – Americans Abroad Hit Hard

Looking for Mr. FBAR:  FBAR Filings for Trustees, Beneficiaries & Trust Grantors

My earlier post set out certain details about the responsibility for a trust to file the Report of Foreign Financial Accounts (Form 114), or FBAR, with respect to foreign accounts it owns or is deemed to own under the FBAR rules.  Today’s discussion covers the situation when trustees, trust beneficiaries and grantors (i.e., the trust … Continue reading Looking for Mr. FBAR:  FBAR Filings for Trustees, Beneficiaries & Trust Grantors

UAE Federal Corporate Tax: How Will it Impact the US Taxpayer? Part II

As discussed in my prior blog post, full details here, on January 31, the United Arab Emirates (UAE) Ministry of Finance announced the introduction of a federal corporate tax (CT) on business, to be implemented in June 2023. The UAE is joining the other Gulf Cooperation Council countries (with exception for Bahrain) that collect tax … Continue reading UAE Federal Corporate Tax: How Will it Impact the US Taxpayer? Part II

Timing Considerations for Expatriation, Tax Compliance and Form 8854

I invite readers to enjoy my article, copied below, recently published by Bloomberg Tax in the Daily Tax Report.  Reproduced with permission. Published January 7, 2022. The Bureau of National Affairs, Inc. (800-372-1033) http://www.bloombergindustry.com It is online here.   My blog post today contains additional input with a link to a podcast on this topic with US … Continue reading Timing Considerations for Expatriation, Tax Compliance and Form 8854

Caught in the US Tax Trap: PART II How Does a Non-US citizen Become a US “Resident” – Taxed on WORLDWIDE Income?

Last week's blog post looked at one way that a non-US citizen can become subject to US income tax on his or her worldwide income - simply by getting a US green card.  Today's post looks at the other way one can fall into the US tax trap. “Substantial Presence” in the US An individual … Continue reading Caught in the US Tax Trap: PART II How Does a Non-US citizen Become a US “Resident” – Taxed on WORLDWIDE Income?

Caught in the US Tax Trap: Part I How Does a Non-US citizen Become a US “Resident” – Taxed on WORLDWIDE Income?

US “residents” are subject to tax on income derived from all sources. That means they are subject to tax on their worldwide income regardless of the source of that income.  So, for example, dividends earned from a French company are taxable, as is gain on the sale of rental property located in Hong Kong; prize money won … Continue reading Caught in the US Tax Trap: Part I How Does a Non-US citizen Become a US “Resident” – Taxed on WORLDWIDE Income?

Coming Soon! Higher Income and Capital Gains Taxes & More – Beware Trusts, Expatriation Planning

The House Ways and Means Committee recently released its proposal (HWM Proposal) to fund the US$3.5 trillion "Build Back Better Act" reconciliation spending package.  Not unexpectedly, the proposal takes aim at high income earners. Here’s a few pointers that are important for many of my readers, especially those with US trusts or those looking at … Continue reading Coming Soon! Higher Income and Capital Gains Taxes & More – Beware Trusts, Expatriation Planning

Senator Warren’s Proposed Wealth Tax and the 40% Tax Hit on Expatriation

The ‘‘Ultra-Millionaire Tax Act of 2021’’ (the “Act”) was proposed by Democratic Senators Elizabeth Warren and Bernie Sanders on March 1 2021.  Like all other tax proposals I have seen in my over 35+ years of tax practice, once the bee is in the bonnet, legislation will inevitably, inexorably, eventually blossom and flourish.  The Act … Continue reading Senator Warren’s Proposed Wealth Tax and the 40% Tax Hit on Expatriation

Expatriation: More than just a Fashionable Trend — Numbers Climb

The number of individuals ending their US status, or “expatriating” continues to rise unabated.  “Expatriates” as used in this context refers to citizens renouncing US citizenship or “long term residents” giving up a green card.  On October 28 the Treasury Department released the names of 732 individuals who “expatriated” during the third quarter of 2020. When … Continue reading Expatriation: More than just a Fashionable Trend — Numbers Climb