Virginia La Torre Jeker, J.D. — US tax matters affecting international clients
When love crosses borders, tax complexity often follows. I know this from first-hand experience having married a Swiss national almost 4 decades ago. When U.S. citizens marry foreign nationals who are not U.S. tax residents a host of U.S. tax rules can upend marital bliss by causing tax compliance complexities that are often difficult to … Continue reading A Complicated U.S. Tax Life: Foreign Spouses And Community Property
Lenders who advance cash to corporations often do so with a clear expectation: the company will repay the principal and will pay interest, and the borrower will report interest income. Yet for U.S. taxpayers the moment of truth comes much later, sometimes years after the money has left the bank—when the IRS, or a court, … Continue reading Corporate ‘Loans’: The Debt v. Equity IRS Challenge And Tax Nightmares
Recent headlines have created alarming concerns among naturalized U.S. citizens. These have suggested that certain tax issues could lead to the loss of U.S. citizenship. This fear is now being amplified on various platforms and stems from a case involving, Vanessa Ben, a Houston woman facing denaturalization over her admission of tax fraud prior to … Continue reading Tax Fraud And Denaturalization Risks: A Balanced View For Taxpayers
The Additional Child Tax Credit can provide taxpayers up to $1,700 per qualifying child in 2025 as a refundable credit. The ACTC not only reduces the amount of tax owed but can also result in a refund from the IRS if the credit exceeds the tax liability. Non-refundable credits can only reduce a taxpayer’s tax … Continue reading Additional Child Tax Credit, Americans Abroad: IRS Is Watching Closely
The Department of Justice and the Internal Revenue Service have recently reaffirmed their strong commitment to pursuing offshore tax evasion through the use of powerful investigative tools. One such tool is the IRS John Doe Summons. On Dec. 23, 2024, the United States District Court for the Southern District of New York granted the IRS authority … Continue reading Offshore Tax Evasion: U.S. Clients Of Trident Trust Target Of IRS John Doe Summons
My article copied below first appeared on Forbes July 12, 2024 – link here. You can follow me on Forbes for free. ~~~~~ The June 20, 2024 report by the Treasury Inspector General for Tax Administration came as a shock to many. The TIGTA report explained that to meet an audit quota set in 2020, … Continue reading IRS Increased Audits Of The Rich: A Flop In Finding Noncompliance
My article copied below, first appeared on Forbes June 11, 2024 – link here. It explains the important rules to know when IRS comes calling to review prior filed tax returns and assess additional taxes. How long can the IRS come after a taxpayer for tax errors or worse? The tax statute of limitations can … Continue reading How Long Does The IRS Have To Catch Your U.S. Tax Mistake? 6 Scenarios
For the past 6 years, the Internal Revenue Service’s (IRS) Large Business and International (LB&I) Division shifted to a new audit strategy known as “campaigns.” This shift in focus concentrates on examining tax issues that will have the broadest impact on tax compliance while making the most efficient use of IRS’s resources. Given funding issues … Continue reading IRS Updates its Audit “Campaign” Targets – Who’s on the List?
The Internal Revenue Service (IRS) was sucker-punched by the Tax Court on April 3, 2023 in the case of Farhy v. Commissioner, 160 T.C. No. 6 (2023). In that case, the Tax Court held that the IRS does not have the authority to assess and collect penalties asserted under Internal Revenue Code Section 6038(b), in the … Continue reading Big Win for Taxpayers with Foreign Assets: IRS Lacks Authority to Assess & Collect Penalties for Failure to File Foreign Information Returns
We have had a taxpayer win in the foreign information reporting arena! I provide a summary of the case of Mr. Krzysztof Wrzesinski below. For readers who wish more, the taxpayer’s complaint is here. Background of the Wrzesinski Case Mr. Wrzesinski (“Taxpayer” or “T”) was a native of Poland who immigrated to the United States … Continue reading Taxpayer Wins! Foreign Gift Not Reported: DOJ Concedes he had “Reasonable Cause”
Virginia - US TAX TALK 