Offshore Tax Evasion: U.S. Clients Of Trident Trust Target Of IRS John Doe Summons

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 →

Breaking! Residence-Based Taxation for Americans Abroad May Become Reality

Representative Darin LaHood just introduced on December 18 the Residence-Based Taxation for Americans Abroad Act, aiming to modernize the US tax system for Americans living overseas. This proposal seeks to shift from the current citizenship-based taxation—which taxes US citizens on their worldwide income regardless of residence—to a residency-based system. The existing US tax framework has … Continue reading Breaking! Residence-Based Taxation for Americans Abroad May Become Reality →

Late Form 3520 Foreign Gifts And Bequests, Good News From IRS

The IRS Commissioner Danny Werfel announced some good news for taxpayers at the end of October 2024. The IRS has ended its practice of automatically assessing penalties when a taxpayer voluntarily submits a late Form 3520, Part IV. This form deals with the obligation of U.S. persons to report to the IRS the receipt of … Continue reading Late Form 3520 Foreign Gifts And Bequests, Good News From IRS →

Bitcoin Jesus Challenges Constitutionality Of Expatriation “Exit Tax”

Roger Ver, an early Bitcoin investor renowned as “Bitcoin Jesus” for his evangelism of cryptocurrency since 2011, now finds himself in a legal maelstrom. Ver, a controversial figure in the blockchain world, was arrested in April 2024 in Spain on U.S. criminal charges stemming from allegations of mail fraud, tax evasion, and filing false tax … Continue reading Bitcoin Jesus Challenges Constitutionality Of Expatriation “Exit Tax” →

Americans Living Abroad: Foreign Housing Tax Break, Explained

Overseas Americans are entitled to certain tax breaks assuming various qualifications are met. One of the significant tax breaks is the ability to exclude from taxable income certain amounts provided by an employer for foreign housing. Housing costs are “personal” in nature and the tax laws do not provide exclusions or deductions for personal expenditures. A … Continue reading Americans Living Abroad: Foreign Housing Tax Break, Explained →

Giving Up US Citizenship – The Path Gets More Complex As DS-4079, Now 18 Pages, Is Revamped

The new procedure for obtaining a Certificate of Loss of US Nationality (CLN) effective November 1, 2024, revolves around an updated Form DS-4079. This "redesigned" form now has tailored sections for different types of expatriating acts, reflecting a more specific and perhaps a more streamlined approach to processing renunciations and relinquishments. Briefly, US citizenship can … Continue reading Giving Up US Citizenship – The Path Gets More Complex As DS-4079, Now 18 Pages, Is Revamped →

IRS Just Launched Pass-Through Compliance Unit: Heightened Focus on Trusts Including Foreign Foundations

The IRS has established a new pass-through compliance unit within its Large Business and International division, as announced on October 22, 2024. This unit aims to tackle “complex financial arrangements”, targeting high-net-worth individuals and entities that use partnerships, S-corporations, and trusts to reduce their tax burdens. Funded by the Inflation Reduction Act, the initiative seeks … Continue reading IRS Just Launched Pass-Through Compliance Unit: Heightened Focus on Trusts Including Foreign Foundations →

Surrender Green Card At The Border: Form I-407, U.S. Tax Expatriation

U.S. immigration law assumes that a person admitted to the United States as a lawful permanent resident (green card holder) will live there permanently. Remaining outside the United States for an extended period, may possibly result in a loss of LPR status. Long periods spent outside of America can result in problems upon re-entry at the … Continue reading Surrender Green Card At The Border: Form I-407, U.S. Tax Expatriation →

Need an FBAR Escape Hatch?

The Report of Foreign Bank and Financial Accounts (FinCEN Form 114) commonly called the FBAR is a crucial reporting requirement for US persons (citizens, green card holders and those meeting the substantial presence test) with foreign financial accounts. With the deadline for the 2023 FBAR set for October 15, my Forbes article provides information to … Continue reading Need an FBAR Escape Hatch? →

Americans Abroad, Tax Scams And IRS’ New Coalition To Combat Tax Fraud

Cybercrime and fraudulent activities continue to evolve and expand. Protecting taxpayers has become an increasingly complex challenge for both governmental authorities and those in the tax profession. Recognizing this, in mid-August the IRS spearheaded the formation of the Coalition Against Scam and Scheme Threats. CASST is an outgrowth of the Security Summit, a public-private initiative … Continue reading Americans Abroad, Tax Scams And IRS’ New Coalition To Combat Tax Fraud →