Virginia La Torre Jeker, J.D. — US tax matters affecting international clients
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
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
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!
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
Digital assets and FBAR reporting are definitely on the horizon but as yet, have not arrived. With the various announcements by the Internal Revenue Service (IRS) that focus on the proper tax reporting for digital assets, as well as delaying implementation of third party broker reporting, it makes total sense that the Financial Crimes Enforcement … Continue reading Digital Asset Reporting for Mr. FBAR @FinCEN
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 United States Supreme Court has just set the stage for sky high FBAR penalties. How did this happen? Let's take a look - The case of United States v. Toth, No. 21-1009 (1st Cir. 2022) was on appeal to the US Supreme Court. The focus of the appeal was that the FBAR penalty was … Continue reading FBAR Penalties – US v. Molyneux and the Big Fat Money Grab
The Taxpayer Advocate Service (TAS) recently released its 2022 report to Congress. In one portion of the Report (listed in “Most Serious Problems Encountered by Taxpayers” #10 OVERSEAS TAXPAYERS: Taxpayers Outside of the United States Face Significant Barriers to Meeting Their U.S. Tax Obligations) TAS provided a succinct review of the problems faced by American … Continue reading Am I Being Cynical? Serious Problems Acknowledged -Too Little, Too Late for Taxpayers Outside the US
My latest article is copied below in full, as published by Bloomberg Tax, December 9, 2022 in Tax Insights, reproduced with permission, link here.The Bureau of National Affairs, Inc. (800-372-1033) http://www.bloombergindustry.com The growing trend of email and phone scammers, combined with the potential for diminished cognitive abilities due to aging, can imperil elderly people’s financial … Continue reading US Tax – Safeguarding Finances of the Elderly, Stateside and Abroad
Last week's blog post, here, examined some of the weapons the Internal Revenue Service (IRS) can use to collect taxes when the uncooperative taxpayer and assets are located abroad. Today we look at some other possible remedies. Is There Any US Connection to Foreign Banks? The IRS can issue a levy notice to any bank … Continue reading Foreign Assets — How Can the IRS Enforce Tax Collection Overseas? (Part II)
Virginia - US TAX TALK 