IRS is Ruthless in Seeking “Willful” FBAR Penalties – But the Court Won’t Have it….

We have another important FBAR case, US v Katholos No17cv531 WDNY Aug 10 2022. Ms Katholos was first introduced to my readers in 2018 (blog post here). An update on Katholos was posted just last week detailing a court’s clarification, perhaps an expansion, of the definition of “financial interest” in an account requiring FBAR reporting. … Continue reading IRS is Ruthless in Seeking “Willful” FBAR Penalties – But the Court Won’t Have it…. →

What Can Happen if Your Streamlined Submission Goes Belly-Up? (Part I)

The IRS Streamlined Procedure, whether the Streamlined Foreign Offshore Procedure (SFOP) or the Streamlined Domestic Offshore Procedure (SDOP) of 2014 is still available for taxpayers, but the Internal Revenue Service (IRS) is apparently closely policing those who enter the program. The IRS is now very carefully vetting the cases coming in. A hallmark of the … Continue reading What Can Happen if Your Streamlined Submission Goes Belly-Up? (Part I) →

Foreign Loans & Mortgages – Foreigners Residing in US / Expats Returning to US…. Surprise! US Withholding Tax Required on Interest Payments?

Many Americans living abroad purchase properties in their foreign country of residence. They often accomplish this with financing from a financial institution located in the country where the property was purchased. Later, they may return to the US and continue holding the property and meeting their mortgage payments. Similarly, many non-US citizens purchase properties with … Continue reading Foreign Loans & Mortgages – Foreigners Residing in US / Expats Returning to US…. Surprise! US Withholding Tax Required on Interest Payments? →

Expatriation and Tax Compliance – IRS Fails to Process the Tax Return

As a tax practitioner I have assisted many taxpayers for decades with expatriation issues (i.e., relinquishing US citizenship or a green card held for at least 8 tax years). In the best case scenario, the taxpayer can avoid being treated as a "covered expatriate" (CE). Sometimes tax planning, correcting tax returns or submitting delinquent international … Continue reading Expatriation and Tax Compliance – IRS Fails to Process the Tax Return →

Timely US Tax Filings: What are the Rules for Taxpayers in Foreign Countries?

Quite often, US taxpayers living in a foreign country are faced with tight deadlines for timely filing of tax returns, refund claims, documents and the like with the Internal Revenue Service (IRS) before the statute of limitations expires. They are often confused as to how to send these physical documents to the IRS and be … Continue reading Timely US Tax Filings: What are the Rules for Taxpayers in Foreign Countries? →

Timing Considerations for Expatriation, Tax Compliance and Form 8854

I invite readers to enjoy my article, copied below, recently published by Bloomberg Tax in the Daily Tax Report. Reproduced with permission. Published January 7, 2022. The Bureau of National Affairs, Inc. (800-372-1033) http://www.bloombergindustry.com It is online here. My blog post today contains additional input with a link to a podcast on this topic with US … Continue reading Timing Considerations for Expatriation, Tax Compliance and Form 8854 →