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

IRS Slipshod Work and Document Destruction Can Mean Big Problems – Especially for Expatriates

The Treasury Inspector General for Tax Administration (TIGTA) has been documenting some careless work being carried out by the Internal Revenue Service (IRS).  We have the most recent TIGTA report (Number 2022-40-036) of May 4, 2022 reporting that the IRS destroyed 30 million “paper-filed information return documents” without bothering to process them beforehand. This destruction … Continue reading IRS Slipshod Work and Document Destruction Can Mean Big Problems – Especially for Expatriates

Foreign Accounts and Assets: How I Approach a “Streamlined” Tax Filing Nowadays

The Internal Revenue Service (IRS) Streamlined Procedures of 2014 are still available for taxpayers with tax noncompliance issues that involve unreported income from a foreign financial asset. The Procedures can help taxpayers who have not filed certain information returns associated with the foreign asset (e.g., Form 8938; Form 5471 pertaining to ownership in a foreign … Continue reading Foreign Accounts and Assets: How I Approach a “Streamlined” Tax Filing Nowadays

Escaping the USA, Exit Tax and Transfer Tax Regimes: Using the “Dual National” Exception

Join me today in a live webinar: Everything you need to know about giving up a green card or US citizenship  - 2 CPE credits. Register here. The economy is not looking good with the stock market dropping sharply, with tech companies being hit most dramatically, dropping by about 40%.  Crypto markets are also in … Continue reading Escaping the USA, Exit Tax and Transfer Tax Regimes: Using the “Dual National” Exception

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