Virginia La Torre Jeker, J.D. — US tax matters affecting international clients
In the heart of America’s immigration debate, a lesser-known but seismic issue is emerging. The intersection of denaturalization and the expatriation tax regime is an explosive topic that has not yet been explored. If the expatriation regime applies to a denaturalized citizen, it imposes an exit tax through a deemed sale of worldwide assets as … Continue reading Denaturalized Citizens Forced To Exit, Can’t Escape Exit Tax
The U.S. Tax Court decided Soroban Capital Partners LP v. Commissioner (T.C. Memo 2025-52) in May 2025 leaving financial, tax and legal advisors concerned. The court upended assumptions about the self-employment tax exemption for limited partners in hedge funds, and by analogy to venture capital, and private equity partnerships both in the U.S. and abroad. U.S. … Continue reading New Self-Employment Tax Risks For U.S. Investors In Global Funds
For some time, foreigners have been drawn to the U.S. real estate market due to its stability, potential for appreciation, and the reliable legal framework in America. A frequently used investment vehicle is a single-member limited liability company created under the laws of a U.S. state. A SMLLC offers liability protection and flexibility. The U.S. … Continue reading Tax Challenges: Foreign Owned U.S. Real Estate Via Single-Member LLC
Foreign investors can win big with United States investments. While holding U.S. assets can be lucrative, the U.S. estate tax regime is complex and often misunderstood by nonresident alien investors. NRAs, those who are neither U.S. citizens nor residents for estate tax purposes, are often very surprised when they learn of the challenges imposed by the … Continue reading 5 U.S. Estate Tax Surprises For Nonresident Alien Investors
Learn all about FBAR and expand services to your clients with confidence. Maybe even land Pope Leo XIV as a new client since his Holiness probably has to file FinCEN Form 114 for the Vatican Bank's accounts. Understand your own compliance risks and what to do if you are not compliant. This is the FBAR … Continue reading WEBINAR – Back By Popular Demand FBAR, FBAR, FBAR!
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
A recent decision reminds taxpayers and the tax compliance community of the importance of filing the Report of Foreign Bank and Financial Accounts. The U.S. District Court for the Southern District of New York in United States v. Hendler, 23 Civ. 3280 (Sept. 17, 2024) has clarified the enduring nature of penalties tied to FBAR. … Continue reading The Hendler Case: FBAR Penalties Survive Beyond Death
When it comes to estate planning, how you hold property with others can have significant tax implications after you have passed on. Internal Revenue Code Section 2040 governs how joint ownership of property with right of survivorship is treated for federal estate tax purposes. The rules can catch even the most astute investors off guard. … Continue reading Understanding Joint Ownership And Estate Tax: Deep Dive Into The Rules
A very informative podcast - I would say it's a crash course on the US #expatriation regime including the recently issued final IRS regs on the Sec. 2801 transfer tax, lots of tax tips including gifting issues to get below USD 2 million threshold, what NOT TO DO if CBP wants you to sign I-407 … Continue reading PODCAST! Crash Course Info! Renouncing US Citizenship / Relinquishing Green Card – Beware The Exit Tax and More
A portion of an individual’s U.S. Social Security retirement, survivors, or disability benefits may be subject to U.S. income tax, regardless if the individual is a U.S. or non-U.S. person. Before delving into the details about tax on Social Security, it is helpful to understand the different nomenclature when it comes to certain benefits. Social … Continue reading Giving Up Citizenship Or Green Card: Harsh Tax On Social Security
Virginia - US TAX TALK 