Looking for Mr. FBAR: When Does a Trust Have a Duty to File?

My latest article on our good friend, Mr. FBAR, is copied below in full, as published by Bloomberg Tax February 21, 2022 in the Daily Tax Report Reproduced with permission, The Bureau of National Affairs, Inc. (800-372-1033) http://www.bloombergindustry.comResponsibility for filing the Report of Foreign Financial Accounts Form 114, or FBAR, is governed by the rules … Continue reading Looking for Mr. FBAR: When Does a Trust Have a Duty to File? →

UAE Federal Corporate Tax: How Will it Impact the US Taxpayer? Part II

As discussed in my prior blog post, full details here, on January 31, the United Arab Emirates (UAE) Ministry of Finance announced the introduction of a federal corporate tax (CT) on business, to be implemented in June 2023. The UAE is joining the other Gulf Cooperation Council countries (with exception for Bahrain) that collect tax … Continue reading UAE Federal Corporate Tax: How Will it Impact the US Taxpayer? Part II →

UAE Federal Corporate Tax: How Will it Impact the US Taxpayer? Part I

My most recent article, co-authored with Clarence Ellis and published by Bloomberg, is copied in full below. The article examines in unique detail the latest news in the tax world of the United Arab Emirates (UAE), which announced it will start to impose tax on business enterprises in the Emirates. Before you read the full … Continue reading UAE Federal Corporate Tax: How Will it Impact the US Taxpayer? Part I →

Overview: The Disregarded Entity & Check-the-Box

What Is a Disregarded Entity? How is it Used in US Tax Planning? Certain business entities can be treated as “nonexistent” for federal income tax purposes. That is, from a US tax perspective, they are simply “disregarded” and the entity is ignored by the Internal Revenue Service (IRS). For other purposes, the entity is not disregarded, … Continue reading Overview: The Disregarded Entity & Check-the-Box →

Timely US Tax Filings: What are the Rules for Taxpayers in Foreign Countries?

Quite often, US taxpayers living in a foreign country are faced with tight deadlines for timely filing of tax returns, refund claims, documents and the like with the Internal Revenue Service (IRS) before the statute of limitations expires. They are often confused as to how to send these physical documents to the IRS and be … Continue reading Timely US Tax Filings: What are the Rules for Taxpayers in Foreign Countries? →

FBAR Traps: International Couples, Powers of Attorney

Meet the Zuhovitzky’s, the quintessential international couple: Jonathan (a naturalized US citizen and Israeli citizen living in Germany) and Esther (an Austrian and Israeli citizen who was never a US citizen or resident). I blogged about them and the IRS’ aggressive stance on asserting so-called FBAR penalties against Jonathan for having a power of attorney … Continue reading FBAR Traps: International Couples, Powers of Attorney →

Timing Considerations for Expatriation, Tax Compliance and Form 8854

I invite readers to enjoy my article, copied below, recently published by Bloomberg Tax in the Daily Tax Report. Reproduced with permission. Published January 7, 2022. The Bureau of National Affairs, Inc. (800-372-1033) http://www.bloombergindustry.com It is online here. My blog post today contains additional input with a link to a podcast on this topic with US … Continue reading Timing Considerations for Expatriation, Tax Compliance and Form 8854 →

Covered Expatriates, Exit Tax and the Principal Residence

My earlier blog post discussed the rules that apply to a US taxpayer who sells his personal residence, whether located abroad or in the US. If the home qualifies as the “principal residence” and other requirements are satisfied the taxpayer may exclude up to US$250,000 ($500,000 for joint returns) of taxable gain from income. As … Continue reading Covered Expatriates, Exit Tax and the Principal Residence →

FBAR – Fifth Circuit, Non-Willful Penalty Multiplies “Per Account” in Bittner Case

Ka’Ching! It’s a win for the Internal Revenue Service (IRS)! At the end of November, in United States v. Bittner, (No. 20-4059, 5th Cir. 11/30/21), the Fifth Circuit overruled the lower court and held that the FBAR non-willful US$10,000 penalty applies on a per account rather than a per form basis. The taxpayer was hit … Continue reading FBAR – Fifth Circuit, Non-Willful Penalty Multiplies “Per Account” in Bittner Case →

Malta Pension Plan – IRS Knocks It Out.. and Yes, “I Told You So…..”

Just in time for Christmas, we have two big gifts. Both relate to Malta Pension Plan schemes. If you are too busy to read the post because of the Christmas rush, in a nutshell, they've just been knocked out and the Internal Revenue Service (IRS) is hot on the trail for taxpayers who used them! … Continue reading Malta Pension Plan – IRS Knocks It Out.. and Yes, “I Told You So…..” →