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 →

11th Circuit Holds FBAR Penalties Are Subject to the Excessive Fines Clause: A Significant Taxpayer Weapon

A recent decision from the 11th Circuit in United States v. Isac Schwarzbaum brings a major development in FBAR (Foreign Bank Account Reporting) penalties and their relationship with the Eighth Amendment's Excessive Fines Clause. The court's holding that FBAR penalties are subject to this constitutional protection under the Excessive Fines Clause is significant, offering taxpayers … Continue reading 11th Circuit Holds FBAR Penalties Are Subject to the Excessive Fines Clause: A Significant Taxpayer Weapon →

Filing A U.S. Tax Return – Even When Not Required – A Very Smart Move

Many taxpayers, especially retirees living abroad, may find themselves in a situation in which their income is too low to meet the threshold for filing a U.S. tax return. Retirees who only receive Social Security income (or small amounts of other additional income), for example, often fall below the tax filing requirement. Understandably, many people … Continue reading Filing A U.S. Tax Return – Even When Not Required – A Very Smart Move →

Green Card Holder Works Abroad: Tricky U.S. Tax And Immigration Issues

Navigating the intricacies of U.S. tax laws can be challenging, especially for green card holders living abroad. Green card holders have concerns that remaining outside the United States for too long may result in loss of the green card. One area that often causes confusion for green card holders is the “foreign earned income exclusion,” … Continue reading Green Card Holder Works Abroad: Tricky U.S. Tax And Immigration Issues →

The Scary Truth About Navigating IRS Tax Guidance

My article is copied in full below. It first appeared on Forbes July 24, 2024 – link here. You can follow me on Forbes for free. Imagine this: You have a pressing tax question and, like many, you turn to Google. Among the plethora of results, you spot information from the IRS, including its … Continue reading The Scary Truth About Navigating IRS Tax Guidance →

IRS Increased Audits Of The Rich: A Flop In Finding Noncompliance

My article copied below first appeared on Forbes July 12, 2024 – link here. You can follow me on Forbes for free. ~~~~~ The June 20, 2024 report by the Treasury Inspector General for Tax Administration came as a shock to many. The TIGTA report explained that to meet an audit quota set in 2020, … Continue reading IRS Increased Audits Of The Rich: A Flop In Finding Noncompliance →