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

Outrunning (and Outwitting) the IRS Using the Statute of Limitations

With tax returns either filed, in progress for Americans abroad, put on extension... (or late because an extension was not properly filed), now is a good time to look at the various statutes of limitations (SOL) applicable to US tax matters. What is a tax SOL?  Simply, the SOL prescribes the length of time permitted … Continue reading Outrunning (and Outwitting) the IRS Using the Statute of Limitations

Should A Green Card Holder Use the Foreign Earned Income Exclusion?

This is actually a difficult question to answer, despite the fact that many green card holders give little thought to the issue and willy-nilly claim the exclusion.  Let's look at some background.  Americans working abroad may be eligible to exclude from US taxable income certain foreign earned income (wages, compensation for services) under the rules … Continue reading Should A Green Card Holder Use the Foreign Earned Income Exclusion?

Head’s Up! IRS Just Revised EIN Application Procedure & Foreign Taxpayers Will Struggle

Effective as of May 13, taxpayers can no longer request an employer identification number (EIN) unless the "responsible party" named on the application has either a Social Security Number (SSN) or Individual Taxpayer Identification Number  (ITIN). Only governmental entities and the military are exempt from this requirement, and may continue to list non-individual entities as … Continue reading Head’s Up! IRS Just Revised EIN Application Procedure & Foreign Taxpayers Will Struggle

Foreign Earned Income Exclusion: What is “Earned Income”?

Americans working abroad may be eligible to exclude certain foreign earned income (wages, compensation for services) from US taxable income under the rules governing the Foreign Earned Income Exclusion (FEIE).  The FEIE amount is adjusted annually for inflation. The amount for 2018 is US$104,100 per individual; for 2019 the amount is US$105,900 per individual.  In … Continue reading Foreign Earned Income Exclusion: What is “Earned Income”?

House Blocks IRS Free-File Tax Help: Who Cares!

In early April, the House of Representatives passed a bill that would re-design the Internal Revenue Service (IRS). It had a nifty and promising title, the "Taxpayer First Act of 2019".  Despite its sweet title, part of the bill would prohibit the IRS from providing taxpayers with free tax preparation software. The for-profit tax preparation … Continue reading House Blocks IRS Free-File Tax Help: Who Cares!

Americans Abroad: Separate But (Not) Equal

I will be posting here a series of eight related videos which discuss the premise that the United States is imposing a separate and more punitive tax system on U.S. dual citizens who live in (and are tax residents of) other countries. The videos were motivated by recent posts by Toronto lawyer John Richardson and … Continue reading Americans Abroad: Separate But (Not) Equal