US Tax Treatment: Stock Options from Your Foreign Employer

With more and more expatriates working outside the United States, many tax questions arise when an employee is given options to buy stock in the foreign company employer. Stock options are increasingly becoming an important element of the international executive’s compensation package. There are wonderful opportunities to be had with stock options, but there are … Continue reading US Tax Treatment: Stock Options from Your Foreign Employer →

Foreign Foundations — What are they for US Tax Purposes? Should I Care? Recent Court Case Lays it Out

Today’s post looks at the case of Rost v United States, No 119-CV-0607-RP 2021 BL 435976 (WD Tex., Austin Div., September 22, 2021). In the Rost case, the Internal Revenue Service ("IRS") assessed close to USD597,000 in civil penalties for a US taxpayer’s failure to file IRS Forms 3520 and 3520-A, information reporting with regard … Continue reading Foreign Foundations — What are they for US Tax Purposes? Should I Care? Recent Court Case Lays it Out →

Double Whammy – US Owner and Beneficiary of Foreign Trust Held Liable for 2 Separate Penalties! Failure to Report as “Owner” and Failure to Report as “Beneficiary”

When a US person has any involvement in any way with a foreign trust, extreme care is required to make sure that all of the strict US tax filing responsibilities are met. Surprisingly, for US tax purposes, a trust can be treated as “foreign” even if it is created in the US under US laws. … Continue reading Double Whammy – US Owner and Beneficiary of Foreign Trust Held Liable for 2 Separate Penalties! Failure to Report as “Owner” and Failure to Report as “Beneficiary” →