Tag: IRS

Taxpayer Wins! Foreign Gift Not Reported: DOJ Concedes he had “Reasonable Cause”

We have had a taxpayer win in the foreign information reporting arena! I provide a summary of the case of Mr. Krzysztof Wrzesinski below.  For readers who wish more, the taxpayer’s complaint is here. Background of the Wrzesinski Case Mr. Wrzesinski (“Taxpayer” or “T”) was a native of Poland who immigrated to the United States … Continue reading Taxpayer Wins! Foreign Gift Not Reported: DOJ Concedes he had “Reasonable Cause” →

Expatriation, Form 8854 & Fair Market Valuation of Assets – Which Date is Used?

The title of this post could also be “What a Difference a Day Makes”. Most of my readers are quite familiar with the expatriation regime, as I have written many blog posts on this topic.   Before delving into the question of the date to use when working through Form 8854, let’s have a quick review … Continue reading Expatriation, Form 8854 & Fair Market Valuation of Assets – Which Date is Used? →

FATCA Statute of Limitations: IRS’ 2018 Assessment Grabs Tax & Penalties Back to 2003

In Fairbank v. Commissioner, T.C. Memo. 2023-19, Dkt. No. 13400-18  (February 23, 2023) the Internal Revenue Service (IRS) issued a notice of deficiency in April 2018 for taxable years 2003, 2004, 2005, 2006, 2007, 2008, 2009, and 2011.  The taxpayers argued the IRS could not go back to these prior years, challenging the assessments on … Continue reading FATCA Statute of Limitations: IRS’ 2018 Assessment Grabs Tax & Penalties Back to 2003 →

Tax Statutes of Limitation – Run Fast, IRS is Right Behind You

With tax season in full swing, now is a good time to review the various civil statutes of limitations (SOL) rules that apply to US tax matters.  Perfect timing to review because we also have a Tax Court case from last month showing how harsh the consequences of the SOL can be if a taxpayer … Continue reading Tax Statutes of Limitation – Run Fast, IRS is Right Behind You →

Free for You: My Cross-Border Tax Presentation for the Financial Planning Association

On March 15, I was delighted to present cross-border tax topics of interest for the Financial Planning Association (FPA).  FPA is a well-known membership organization for certified financial planner professionals and those engaged in the financial planning process.  It provides its members with practice support, learning, advocacy, and networking. As a tax professional, with 40 … Continue reading Free for You: My Cross-Border Tax Presentation for the Financial Planning Association →

The Perfect Storm – US Tax, Community Property & the Mobile International Couple  

Last week I blogged about how the US tax system can create serious tax problems for the international couple when one is a US person and the other is not.  In order to keep things simple, it is often advised that the couple hold assets separately to avoid nasty US tax complications. However, in some … Continue reading The Perfect Storm – US Tax, Community Property & the Mobile International Couple   →

Treaty Tie-Breaker is an FBAR Escape Hatch, Says the Court!

It has been the position of the Internal Revenue Service (IRS) that a “Report of Foreign Bank and Financial Accounts” (Form 114), commonly called the “FBAR”, must still be filed to report any foreign accounts, despite a green card holder’s treaty tie-breaker claim. It came as a big surprise to me that the United States … Continue reading Treaty Tie-Breaker is an FBAR Escape Hatch, Says the Court! →

BREAKING! US Supreme Court — FBAR “Nonwillful” Penalty is Per Form and NOT Per Account

What we have all been waiting for!  Bittner v. United States was just decided hours ago by the United States Supreme Court! An amazing taxpayer win.  It is late here in the Middle East, so I provide only the information you need to know!  You can read the full case here. The Bank Secrecy Act … Continue reading BREAKING! US Supreme Court — FBAR “Nonwillful” Penalty is Per Form and NOT Per Account →

More of the Latest:  Digital Asset Reporting for Mr. Taxman @IRS

A survey conducted by CoinLedger of US crypto crypto investors found that only 58% of the sample size reported crypto holdings on their taxes in 2022. That was an improvement of 4% year-over-year. Meanwhile, 31% did not report (11% would not answer).  Let's look at the non-reporters: 50% said the primary reason was that they … Continue reading More of the Latest:  Digital Asset Reporting for Mr. Taxman @IRS →

The Latest: Broker Reporting of Digital Assets and Deducting Crypto Losses

Today’s post provides an update on some important US tax issues relevant to digital assets. While the Internal Revenue Service (IRS) continues its crackdown on digital asset tax reporting, the controversial broker tax reporting rules for digital assets have been postponed. It looks like we will be in for a wait!  Today’s post provides the … Continue reading The Latest: Broker Reporting of Digital Assets and Deducting Crypto Losses →