Life Gets Complicated When a Foreign Country’s Laws Impact US Tax

Transactions now span the globe with the tap of a key on an I-Phone; families are multi-national, with many living in different parts of the world at different stages in their careers and lives; virtual currency has become official legal tender in at least one country, the United States has de facto imposed enforcement of … Continue reading Life Gets Complicated When a Foreign Country’s Laws Impact US Tax

Have you Expatriated or Thinking of Expatriating? IRS Now Looking Closely

On July 19th, the Internal Revenue Service (IRS) through its Large Business and International (LB&I) Division announced six new “compliance campaigns” for taxpayers. Significantly, one of these campaigns targets “expatriation”, and apparently reaches back to those who “expatriated” on or after June 17, 2008.  The campaign will be looking at “expatriates” – US citizens who … Continue reading Have you Expatriated or Thinking of Expatriating? IRS Now Looking Closely

IRS Website = Unreliable, Legal Weight = Zilch

The stress of tax filing time had been on full throttle in April, and taxpayers abroad were scrambling to meet the tax filing deadline in June ... many taxpayers are on extension until October.  Here's a familiar scenario: You need to find an answer to a tax question and turn to your good friend, Mr. … Continue reading IRS Website = Unreliable, Legal Weight = Zilch

US Immigrant’s Residency Starting Date – The Devil’s Details – Too Many Days in the USA?

Part I of this blog post examined the importance of the Residency Starting Date (RSD) and how it applied under the Green Card Test. It also pointed out that traps for the unwary can destroy pre-immigration tax planning if one had not correctly nailed down the RSD.  Today's post will examine the RSD rules that apply when … Continue reading US Immigrant’s Residency Starting Date – The Devil’s Details – Too Many Days in the USA?

“Residency Starting Date” – Don’t Leave Home Unless You Understand It!

When a foreign individual commences “residency” in the United States for US Income Tax purposes, this date, the Residency Starting Date (RSD), will mark the official date he begins to be taxed on his worldwide income and becomes responsible for various tax information reporting (such as FBAR, Form 5471, Form 8938, to name a few).  Commencing on this … Continue reading “Residency Starting Date” – Don’t Leave Home Unless You Understand It!

Getting an ITIN When Overseas: Help!

Today's post looks at the US Internal Revenue Service (IRS) options available to taxpayers residing abroad who need an “Individual Taxpayer Identification Number” (ITIN) to fulfill their US tax filing duties.  There are 3 basic options (i) mailing the completed Form W-7, “Application for Individual Taxpayer Identification”, and required identification documents to the IRS (ii) … Continue reading Getting an ITIN When Overseas: Help!

Expatriation: Deferring Payment of the Exit Tax

I recently blogged about the debate between Prof. Edward Zelinsky and John Richardson as it pertained to the Exit Tax imposed on so-called "covered expatriates".  This was in the broader context of the US income taxation model which is based on one's "citizenship" rather than one's residence. The thrust of my earlier blog post concerned … Continue reading Expatriation: Deferring Payment of the Exit Tax

Americans Overseas: Timely Filing of Tax Returns and Other Documents With the IRS

Quite often, US taxpayers living in a foreign country are faced with tight deadlines for filing their paper tax returns.  They are often confused as to how to send these physical documents to the Internal Revenue Service (IRS) and be considered to have sent them in a timely fashion when the foreign (i.e., non-US) post … Continue reading Americans Overseas: Timely Filing of Tax Returns and Other Documents With the IRS

Attorney-Client Privilege & John Doe: Your Secret Is Safe … But Your Identity Isn’t!

Most of my readers are aware of the “attorney-client privilege”. Generally speaking, the privilege preserves the confidentiality of communications between a lawyer and her clients.  When the privilege is in place, attorneys may not divulge their clients’ secrets and cannot be "forced" to divulge them (for example, in a court proceeding or to the Internal … Continue reading Attorney-Client Privilege & John Doe: Your Secret Is Safe … But Your Identity Isn’t!

It’s About Time! Clearer Tax Guidance for Cryptocurrency…. on the Way

Internal Revenue Service (IRS) commissioner Charles Rettig announced that the IRS plans to issue further guidance on the taxation of cryptocurrency.   Commissioner Retting wrote that “We have been considering these issues and intend to publish guidance addressing these and other issues soon.” Can it be? Is an "IRS rescue" really on the way? Will it … Continue reading It’s About Time! Clearer Tax Guidance for Cryptocurrency…. on the Way