COVID-19 restrictions have severely limited services at US embassies and consulates around the world. As a result, renouncing one’s US citizenship has become very difficult, and in many cases, just about impossible at the current time. This gives individuals more time to make sure they have properly planned for expatriation. It's a big step. I … Continue reading Renouncing One’s US Citizenship: More Audits, Virtual Currency, CLN & Travel
Many of my readers are aware that I have written various blog posts about the US tax issues that surround virtual currency. Some have asked, (perhaps innocently, perhaps not), about so-called “third party reporting” of virtual currency to the Internal Revenue Service (IRS) . For those who do not know what this means – it’s … Continue reading Third Party Reporting of Virtual Currency: Who’s Telling the IRS What?
The US Internal Revenue Service (IRS) released instructions to the draft 2020 Form 1040 on Oct 23rd. It may be recalled that a virtual currency question was introduced for the first time on the 2019 Form 1040 on Schedule 1. Not all taxpayers are required to complete Schedule 1. Now, the 2020 Form 1040 places the question … Continue reading Virtual Currency: IRS Sheds More Light for 2020 Tax Returns
On November 5, the Internal Revenue Service (IRS) made life more difficult for taxpayers who may have missed some foreign information return filings. The IRS quietly revised one of the four options to correct for missing information returns with respect to a US taxpayer’s interest in any offshore/foreign assets and holdings (e.g., Form 8938, Form … Continue reading IRS Stealth: Delinquent Information Submission Procedure Penalties May Apply Without Considering “Reasonable Cause” Statement
Foreign investment in the US real property market is big business. US property sales to foreign buyers in 2019 totaled US$78 billion. A look at statistics from more recent years shows that the largest share of foreign residential investors are from China and Canada, followed by Mexico. The US tax laws apply to foreigners owning … Continue reading IRS Needs Money: NRA’s Owning US Real Estate Will Help the Agency Get it Via Taxes and Penalties
The Internal Revenue Service (IRS) is looking for money. As part of the hunt, it has instituted various “campaigns” (full list here) aimed at areas in which there is greater taxpayer noncompliance that may involve significant tax dollars and penalties. One such campaign involves the failure by a US person to file complex information-reporting tax … Continue reading Foreign Trust Forms 3520 and 3520-A Penalties: A Potential Gold Mine for the IRS
The Treasury Inspector General for Tax Administration (TIGTA) recently issued its report “More Enforcement and a Centralized Compliance Efforts Are Required for Expatriation Provisions”, (Reference Number: 2020-30-071, September 28,2020) telling the Internal Revenue Service (IRS) that it needs to do more to make sure that the rising number of US citizens and long term residents … Continue reading Expatriation – IRS Told to Get Tough and Enforce the Law
By now most of my readers will have some familiarity with Internal Revenue Code Section 965, and the “deemed repatriation” or “transition tax” introduced by the Tax Cuts and Jobs Act (“TCJA”) in 2017. My earlier blog post provided significant detail about this new tax law provision which is intended to move the US international tax … Continue reading Section 965 Transition Tax – Enforcement & Audits Begin Next Month
We know that the Internal Revenue Service (IRS) has been investigating tax evasion and other crimes tied to cryptocurrency. The agency has been hard at work for some time in scrutinizing crypto and for the past two years, it has been in the process of developing and executing investigation techniques to enforce cryptocurrency compliance. Along … Continue reading IRS Wants Help on Cryptocurrency Audits – Seeks Private Crypto Gurus
Cyptocurrency (such as Bitcoin) is a type of virtual currency. This is an emerging area and consequently transactions involving use of crypto come with an enormous amount of US tax uncertainty. The Internal Revenue Service (IRS) has taken a keen interest in virtual currency since its use provides a way for taxpayers to avoid tax … Continue reading IRS’ Crypto Guidance – No, You Cannot Rely On It.