Section 965 Transition Tax – Enforcement & Audits Begin Next Month

By now most of my readers will have some familiarity with  Internal Revenue Code Section 965, and the “deemed repatriation” or “transition tax” introduced by the Tax Cuts and Jobs Act (“TCJA”) in 2017.  My earlier blog post provided significant detail about this new tax law provision which is intended to move the US international tax … Continue reading Section 965 Transition Tax – Enforcement & Audits Begin Next Month

COVID-19: Is Employer Provided Assistance due to the Pandemic Taxable Income? What if the Employer is “Foreign”?

Last week's blog post discussed the home office tax deduction and burst the bubble for many who were working at home for months under COVID-19 restrictions.  Unfortunately, as discussed in that earlier post, this tax break cannot be used by an individual who is an “employee” as opposed to "self-employed".  This restriction is a result … Continue reading COVID-19: Is Employer Provided Assistance due to the Pandemic Taxable Income? What if the Employer is “Foreign”?

COVID-19:  Can I Take a Home Office Deduction? 

In the face of the corona virus, just about everyone I know has been working from home for quite some time. Home can be Stateside or overseas.  Many are now asking if they are entitled to take a tax deduction for their “home office”.  Here’s everything you need to know. The home office tax break … Continue reading COVID-19:  Can I Take a Home Office Deduction? 

Eating Out Again – Yes, the Day Will Come Back… Business Deductions for Entertainment and Meals

In the midst of the COVID-19 pandemic, most everyone is staying home; entertainment and meals outside the home bubble are not on the agenda.  But, someday, life will return to normal and we will eat out again!  The economy will pick up and clients, prospective customers and associates will look to meet and enjoy a … Continue reading Eating Out Again – Yes, the Day Will Come Back… Business Deductions for Entertainment and Meals

GILTI High Tax Kick-Out Election — Kicked Out by Dems!

On February 12, Senate Finance Committee Ranking Member Ron Wyden, D-Ore., and Senator Sherrod Brown, D-Ohio, introduced legislation to prevent the Treasury Department from carving out an exception (commonly called the GILTI High Tax Kick-Out) for multinational companies to escape the so-called GILTI provisions of the Tax Cuts and Jobs Act (TCJA). The title of the … Continue reading GILTI High Tax Kick-Out Election — Kicked Out by Dems!

Repatriation/Transition Tax: IRS Announces Limited “Double Taxation” Relief

NEWS FLASH! The Internal Revenue Service (IRS) announced today that there are limited circumstances in which it may be appropriate to provide relief from "double taxation" resulting from application of the repatriation tax under Internal Revenue Code Section 965, as amended by the Tax Cuts and Jobs Act (TCJA). The IRS has determined that in … Continue reading Repatriation/Transition Tax: IRS Announces Limited “Double Taxation” Relief

ATTENTION! Married Filing Separately? $5 of Gross Income? Must File US Income Tax Return!

Yes, that did read US$5. Not $50. Not $500……This measly number will heavily impact Americans abroad who are married to non-US spouses.  In many instances, the US spouse will file separately and keep the non-US spouse completely out of the US tax picture.  This may not always be the best tax strategy but in some … Continue reading ATTENTION! Married Filing Separately? $5 of Gross Income? Must File US Income Tax Return!

IRS Eye on You! Newest Campaign: Repatriation Tax (IRC Section 965)

Most of my readers have heard about Internal Revenue Code Section 965, and the “deemed repatriation” or “transition tax” introduced by the Tax Cuts and Jobs Act (“TCJA”).  My earlier blog post provided significant detail about this tax law provision which was intended to move the US international tax regime into a “territorial system”.  In making … Continue reading IRS Eye on You! Newest Campaign: Repatriation Tax (IRC Section 965)

US Citizenship And Worldwide Taxation: Justified?

Tune in to the amazing debate between John Richardson and Edward Zelinsky, two renowned tax and citizenship professionals, taking place on Friday May 17.  Not only is it free,  but viewers will receive an unparalleled education about the major issues surrounding US citizenship, its tax consequences for the typical American abroad and Accidental Americans, effects … Continue reading US Citizenship And Worldwide Taxation: Justified?

Overseas Home? Mortgage Interest, Foreign Real Property Taxes & New US Tax Law – Any Workaround?

Sweeping tax reform was signed into law by President Trump on December 22, 2017.  Now that tax returns are being prepared for the 2018 year, individuals are more keenly feeling the impact of the “Tax Cuts and Job Act” (“TCJA”). I’ve had numerous calls on two questions by Americans overseas who own a foreign residence.  … Continue reading Overseas Home? Mortgage Interest, Foreign Real Property Taxes & New US Tax Law – Any Workaround?