Virginia La Torre Jeker, J.D. — US tax matters affecting international clients
The IRS Commissioner Danny Werfel announced some good news for taxpayers at the end of October 2024. The IRS has ended its practice of automatically assessing penalties when a taxpayer voluntarily submits a late Form 3520, Part IV. This form deals with the obligation of U.S. persons to report to the IRS the receipt of … Continue reading Late Form 3520 Foreign Gifts And Bequests, Good News From IRS
Roger Ver, an early Bitcoin investor renowned as “Bitcoin Jesus” for his evangelism of cryptocurrency since 2011, now finds himself in a legal maelstrom. Ver, a controversial figure in the blockchain world, was arrested in April 2024 in Spain on U.S. criminal charges stemming from allegations of mail fraud, tax evasion, and filing false tax … Continue reading Bitcoin Jesus Challenges Constitutionality Of Expatriation “Exit Tax”
Overseas Americans are entitled to certain tax breaks assuming various qualifications are met. One of the significant tax breaks is the ability to exclude from taxable income certain amounts provided by an employer for foreign housing. Housing costs are “personal” in nature and the tax laws do not provide exclusions or deductions for personal expenditures. A … Continue reading Americans Living Abroad: Foreign Housing Tax Break, Explained
The IRS has established a new pass-through compliance unit within its Large Business and International division, as announced on October 22, 2024. This unit aims to tackle “complex financial arrangements”, targeting high-net-worth individuals and entities that use partnerships, S-corporations, and trusts to reduce their tax burdens. Funded by the Inflation Reduction Act, the initiative seeks … Continue reading IRS Just Launched Pass-Through Compliance Unit: Heightened Focus on Trusts Including Foreign Foundations
U.S. immigration law assumes that a person admitted to the United States as a lawful permanent resident (green card holder) will live there permanently. Remaining outside the United States for an extended period, may possibly result in a loss of LPR status. Long periods spent outside of America can result in problems upon re-entry at the … Continue reading Surrender Green Card At The Border: Form I-407, U.S. Tax Expatriation
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
The Report of Foreign Bank and Financial Accounts (FinCEN Form 114) commonly called the FBAR is a crucial reporting requirement for US persons (citizens, green card holders and those meeting the substantial presence test) with foreign financial accounts. With the deadline for the 2023 FBAR set for October 15, my Forbes article provides information to … Continue reading Need an FBAR Escape Hatch?
A recent decision from the 11th Circuit in United States v. Isac Schwarzbaum brings a major development in FBAR (Foreign Bank Account Reporting) penalties and their relationship with the Eighth Amendment's Excessive Fines Clause. The court's holding that FBAR penalties are subject to this constitutional protection under the Excessive Fines Clause is significant, offering taxpayers … Continue reading 11th Circuit Holds FBAR Penalties Are Subject to the Excessive Fines Clause: A Significant Taxpayer Weapon
Many taxpayers, especially retirees living abroad, may find themselves in a situation in which their income is too low to meet the threshold for filing a U.S. tax return. Retirees who only receive Social Security income (or small amounts of other additional income), for example, often fall below the tax filing requirement. Understandably, many people … Continue reading Filing A U.S. Tax Return – Even When Not Required – A Very Smart Move
Navigating the intricacies of U.S. tax laws can be challenging, especially for green card holders living abroad. Green card holders have concerns that remaining outside the United States for too long may result in loss of the green card. One area that often causes confusion for green card holders is the “foreign earned income exclusion,” … Continue reading Green Card Holder Works Abroad: Tricky U.S. Tax And Immigration Issues
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