Form 8938: How This IRS FATCA Weapon is Failing

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 →

What if Someone Dies Owning an Undeclared Foreign Financial Account? What Should The Executor & Heirs Do?

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? →

Can You Claim a Refund of Your “Willful” FBAR Penalty?

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? →

Flying Under the Radar: Personal Use of “Business” Frequent Flyer Miles

Do I have to pay tax on that? Get the full scoop in today's post! “Expat” taxpayers living abroad are often given certain perks from their employers that would not be provided if the individual remained State-side. For example, provision by the employer for airline tickets home for the taxpayer and his/her family; or payment … Continue reading Flying Under the Radar: Personal Use of “Business” Frequent Flyer Miles →

The FATCA Goose Lays a Rotten Egg: Treasury Watchdog Lambasts IRS & US Supreme Court Denies Relief

I have blogged extensively about the “Foreign Account Tax Compliance Act” (FATCA) in the past. Most of my readers know that FATCA was enacted in 2010 but has taken years to implement. The law requires foreign (non-US) financial institutions (FFIs) to report financial accounts owned by US persons (including through entities) to the Internal Revenue … Continue reading The FATCA Goose Lays a Rotten Egg: Treasury Watchdog Lambasts IRS & US Supreme Court Denies Relief →

The J5 International Tax Hunt is On….

Many countries are waking up to the fact that offshore structures, financial instruments, cryptocurrency and other advances in technology, when inappropriately used, are fast outwitting their tax collectors. This wake-up was eventually accompanied by the realization that there is more power in collaboration and in numbers. Who or What is the “J5”? The “Organization for … Continue reading The J5 International Tax Hunt is On…. →