Seriously? IRS Assesses US$5.1 Million FBAR Penalty for “Signature Authority”

I have been keeping readers up to date with the current controversy surrounding imposition of an FBAR penalty for “willful” violations – is it limited to a $100,000 cap or can the penalty, if greater, be assessed at 50% of the value of the unreported account? More detailed background on this issue is available at my … Continue reading Seriously? IRS Assesses US$5.1 Million FBAR Penalty for “Signature Authority”

Warning: Marriage to a ‘Foreigner’ May Be Hazardous to Your Tax Health

Recently, I am seeing more and more married couples of dual nationality (with one US individual partner) struggling with the US tax issues wrought by such a "mixed marriage".  Some are same sex couples married under the laws of a foreign (non-US) jurisdiction.   Believe it or not, marriages taking place in a foreign country (whether … Continue reading Warning: Marriage to a ‘Foreigner’ May Be Hazardous to Your Tax Health

Tax Filing and the Foreign Spouse – “Married Filing Separately” versus “Head of Household”

Tax filing time is upon us! Selecting the best tax filing status is an important element of tax planning and should not be taken lightly.  For US persons who are married to foreigners (so-called "nonresident alien individuals", or "NRA"), special considerations come into play.  Making the decision how to treat your foreign spouse for US … Continue reading Tax Filing and the Foreign Spouse – “Married Filing Separately” versus “Head of Household”

Time to Review! Tax Issues for US Recipients of Gifts/Bequests from Foreigners

With Christmas having recently been on our doorstep, now is the time to review what tax consequences are in store for gift givers and their lucky recipients.  US tax filings might be required of a US individual who receives a gift (whether in cash or property of some kind - you know, a 5 carat … Continue reading Time to Review! Tax Issues for US Recipients of Gifts/Bequests from Foreigners

ATTENTION! Married Filing Separately? $5 of Gross Income? Must File US Income Tax Return!

Yes, that did read US$5. Not $50. Not $500……This measly number will heavily impact Americans abroad who are married to non-US spouses.  In many instances, the US spouse will file separately and keep the non-US spouse completely out of the US tax picture.  This may not always be the best tax strategy but in some … Continue reading ATTENTION! Married Filing Separately? $5 of Gross Income? Must File US Income Tax Return!

OOOOPS! I Received a Gift from a Foreign Corporation (or Foreign Partnership)

Here in the Middle East where I have been practicing for almost two decades, I have seen that it is very common for families to create offshore structures in various countries (outside the USA) to hold a large portion of the family wealth.  The underlying reasons for maintaining these structures outside of the family’s home … Continue reading OOOOPS! I Received a Gift from a Foreign Corporation (or Foreign Partnership)

D is for “Domicile”, Don’t Disregard!

Several of my recent blog posts set the stage showcasing the serious US tax issues that can arise for a married couple when only one  is a US person and they are impacted by application of a foreign country’s community property laws.  You can read these blog posts here, here and here. For example, if funding … Continue reading D is for “Domicile”, Don’t Disregard!

Life Gets Complicated When a Foreign Country’s Laws Impact US Tax

Transactions now span the globe with the tap of a key on an I-Phone; families are multi-national, with many living in different parts of the world at different stages in their careers and lives; virtual currency has become official legal tender in at least one country, the United States has de facto imposed enforcement of … Continue reading Life Gets Complicated When a Foreign Country’s Laws Impact US Tax

Getting an ITIN When Overseas: Help!

Today's post looks at the US Internal Revenue Service (IRS) options available to taxpayers residing abroad who need an “Individual Taxpayer Identification Number” (ITIN) to fulfill their US tax filing duties.  There are 3 basic options (i) mailing the completed Form W-7, “Application for Individual Taxpayer Identification”, and required identification documents to the IRS (ii) … Continue reading Getting an ITIN When Overseas: Help!

US Citizenship And Worldwide Taxation: Justified?

Tune in to the amazing debate between John Richardson and Edward Zelinsky, two renowned tax and citizenship professionals, taking place on Friday May 17.  Not only is it free,  but viewers will receive an unparalleled education about the major issues surrounding US citizenship, its tax consequences for the typical American abroad and Accidental Americans, effects … Continue reading US Citizenship And Worldwide Taxation: Justified?