I have written a few blog posts on the thorny side of filing US income tax returns, FBARs and various information returns when one is married to a non-resident alien (NRA) spouse. It may be helpful to read those posts here and here before embarking on this one as the earlier posts set out some … Continue reading Tax Court, IRS Speak with Forked Tongue? Section 6013(g) Election to Treat Foreign Spouse as US “Resident”
My earlier blog post gave a head’s up to married couples about US tax issues that can arise when assets are owned jointly with a spouse who is not a US citizen. A follow-up blog post detailed the US Gift tax rules that apply when assets are held jointly with right of survivorship (WROS) by a US/non-US citizen … Continue reading Estate Tax Nightmare: Joint Ownership of Property with A Non-US Spouse
For those of you who have been sleeping too much the past few days, let’s wake up and learn a bit about the face-off in Washington DC over the border security wall. Right now, there’s no federal budget in place and funding for many government agencies has disappeared, resulting in partial shutdowns for some, including … Continue reading SHUTDOWN… Last IRS Agent to Leave, Please Turn off the Lights
Bloomberg reports that next year, the US may be put on the Organization for Economic Cooperation and Development’s (OECD) “blacklist” of tax haven countries alongside such notables as Guam and Trinidad and Tobago. The move comes as numerous countries continue to question the United States’ adamant refusal to participate in the international information exchange program, … Continue reading Happy New Year – US to be Blacklisted as a Tax Haven?
As many will remember, the Offshore Voluntary Disclosure Program (OVDP) closed on September 28th with the promise that the Internal Revenue Service (IRS) would issue new guidance on voluntary disclosures made after that date. The guidance just arrived in the form of a 5-page Memorandum by Kristen B. Wielobob, Deputy Commissioner for Services and Enforcement, … Continue reading It’s Finally Here: The IRS Bible for Voluntary Disclosures
Over the summer, I blogged about the newly formed “Joint Chiefs of Global Tax Enforcement”, or the “J5”, for short. Five countries form this international coalition: Australia, Canada, the Netherlands, the United Kingdom, and the United States. The goal of the J5 is to combat transnational tax crime through increased collaboration; in other words, these … Continue reading Newest Targets: “Enablers” and “Cryptocurrencies”
I was recently asked about the tax problems faced by Americans who move overseas. Unfortunately, there are many US tax difficulties faced by Americans abroad. In order to make some sense of this vast topic, let's put the major problems into several basic categories. Once aware of the problems lurking out there, you can get … Continue reading Before You Think of Becoming an “American Abroad”, Read This….
On July 5, 2018, the Treasury Inspector General for Tax Administration ("TIGTA") issued a final audit report covering the enforcement efforts of the US Internal Revenue Service (IRS) of the “Foreign Account Tax Compliance Act” (the infamous "FATCA"). Readers may recall that FATCA was enacted in 2010, but it has been a very rocky road … Continue reading Form 8938: How This IRS FATCA Weapon is Failing
Henry Seggerman has first-hand experience with this type of situation. Without hesitation, my guess is that he’ll tell you to get the Estate into an IRS Voluntary Disclosure Program (“VDP”). Here is the tale of the unenviable case of the Seggermans! Henry was the son of a prominent New York businessman who passed away. Henry was … Continue reading What if Someone Dies Owning an Undeclared Foreign Financial Account? What Should The Executor & Heirs Do?
Below is a copy of my post as it appeared (May 21 2018) on my former blog "Let's Talk About US Tax" hosted by AngloInfo. We had a very interesting case decided May 16 2018 when a district court in Texas granted Dominique Colliot’s motion for summary judgment (United States, v. Dominique G. Colliot). The … Continue reading Can You Claim a Refund of Your “Willful” FBAR Penalty?