Americans Abroad: Taxpayer GILTI Victory Just Announced in Proposed Regulations!

The Internal Revenue Service (IRS) just issued proposed Regulations dealing with the “Deduction for Foreign-Derived Intangible Income and Global Intangible Low-Taxed Income (“GILTI”)”. The proposed regulations mark a big win for Americans running their businesses through foreign corporations. The regulations are scheduled to be published in the Federal Register tomorrow. In part, they address the … Continue reading Americans Abroad: Taxpayer GILTI Victory Just Announced in Proposed Regulations! →

QBI Deduction? Not for the American Abroad! AND Next Year, IRS Will Be Checking Your Numbers!

Section 199A of the Internal Revenue Code was created by the Tax Cuts and Jobs Act (TCJA). If a taxpayer can utilize the new law, the taxpayer can save a bundle in taxes since the provision provides a 20% deduction for so-called “qualified business income” ("QBI”). The American abroad will not be so lucky since … Continue reading QBI Deduction? Not for the American Abroad! AND Next Year, IRS Will Be Checking Your Numbers! →

Americans Abroad – How to Cope With Tax Reform & Save for Education

President Trump’s tax reform (commonly referred to as the "Tax Cuts and Jobs Act", and also known as "TCJA" was signed into law on December 22, 2017. My recent blog post detailed how TCJA revised the “kiddie tax” rules and how the new rules will take a big bite out of a young person’s investment income, … Continue reading Americans Abroad – How to Cope With Tax Reform & Save for Education →

Hot off the Press: IRS User-Friendly Guides Explain TCJA Basics

Tax simplification was an enunciated goal of the Tax Cuts and Jobs Act (TCJA) enacted in December 2017... but it was certainly a goal that remains unmet. The Internal Revenue Service (IRS) itself has estimated that due to TCJA it needs to create or revise more than 400 taxpayer forms, instructions and publications for the … Continue reading Hot off the Press: IRS User-Friendly Guides Explain TCJA Basics →

Your Children, Kiddie Tax and US Tax Reform – Tax, Tax, Tax the Kiddies!

Giving a significant amount of investment assets to one’s children used to be a popular tax strategy, since it permitted the income earned on the investment to be taxed at the child’s presumably lower tax rate. Congress, in its kind-hearted way enacted the so-called “kiddie tax” in 1986 to prevent parents from abusing this strategy. … Continue reading Your Children, Kiddie Tax and US Tax Reform – Tax, Tax, Tax the Kiddies! →

Property Transfers at Divorce and the Foreign (Non-US) Spouse

As if divorce were not a stressful enough time, the complexities of the US tax rules when a non-US spouse is involved just make it all the more unbearable. Keep in mind, too, that foreign divorces can add further legal complexity to the mix and professional help should always be sought. This is so because when foreign … Continue reading Property Transfers at Divorce and the Foreign (Non-US) Spouse →

Foreign Individuals: US Estate Tax Reform Passed You By (Part I)

Prior to the actual passage of the “Tax Cuts and Jobs Act” (TCJA) on December 22 2017, there were some high expectations that the disparity in the US estate tax exemption for US and non-US persons would be eliminated, or that the US estate tax itself would be repealed. Unfortunately, neither of these hoped-for events … Continue reading Foreign Individuals: US Estate Tax Reform Passed You By (Part I) →

Happy New Year – US to be Blacklisted as a Tax Haven?

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? →

PFICs – The Fairytale Definition That Lives Happily Ever After…

I was hoping that tax reform would have done away with, or at least modified, the troublesome provisions surrounding the PFIC or so-called “Passive Foreign Investment Company”. This was not to be and it prompted me to review the PFIC rules and count the ways they cause trouble! What is a PFIC? A PFIC is … Continue reading PFICs – The Fairytale Definition That Lives Happily Ever After… →

Gifting Your Way to Freedom – How TCJA Can Help You Expatriate

Not surprisingly over 1,000 individuals expatriated (gave up US citizenship or long term residency) in the third quarter of 2018. This is according to the most recent “Name and Shame” list published by the US Treasury in the Federal Register on November 19, 2018. Most likely the real number is higher, as the accuracy of … Continue reading Gifting Your Way to Freedom – How TCJA Can Help You Expatriate →