A portion of an individual’s US Social Security retirement, survivors, or disability benefits may be subject to Federal Income tax, regardless if the individual is a US or non-US person. Today’s post looks at the US taxation details on US social security benefits for US and non-US persons. My earlier blog post here discussed the … Continue reading Social Security Benefits Paid to US and Non-US Individuals, Including Those Who Expatriated – How Are They Taxed?
Last week's blog post, here, examined some of the weapons the Internal Revenue Service (IRS) can use to collect taxes when the uncooperative taxpayer and assets are located abroad. Today we look at some other possible remedies. Is There Any US Connection to Foreign Banks? The IRS can issue a levy notice to any bank … Continue reading Foreign Assets — How Can the IRS Enforce Tax Collection Overseas? (Part II)
We have another important FBAR case. The case is significant for 2 distinct reasons 1) clarification, and some may say, an ‘expansion’ of the definition of “financial interest” in an account requiring FBAR reporting and 2) a firm demonstration how far the Internal Revenue Service (IRS) will go to assert a civil “willful” FBAR penalty. … Continue reading Mr. FBAR – He Lurks in Every Corner – Katholos Case Expands Meaning of “Financial Interest”
My earlier blog post discussed some of the complications that arise when certain individuals wish to renounce their US citizenship. The would-be renunciant must give up US citizenship “voluntarily” and with the requisite “intention” in order to meet the legal requirements for an effective renunciation. This can be a difficult hurdle to surmount in the … Continue reading US Citizenship: Do You Really Want It? Brave New World – Assisted Reproductive Technology / Surrogacy / Same-sex Marriage
I am now frequently receiving more and more expatriation inquiries from the foreign parents of a child born in the United States while the parents were studying there or were otherwise in America on some other temporary basis. “Jus soli” (the law of the soil) is a rule of common law followed by the US, under … Continue reading Special Hurdles: Expatriation of Minors / Mentally Challenged Individuals
Part I of this blog post examined the US tax issues faced by the Duke of Sussex who moved with Duchess Meghan to Los Angeles in March 2020. Given the significant number of days of physical presence in America, Prince Harry has most likely already met the "substantial presence test" and is being taxed the … Continue reading Prince Harry (Part II) – Does US Citizenship Wait in the Royal Wings? What about the Impact on the Royal Family?
There are good lessons in today's post for any individual who is considering attaining "US status" - be it by obtaining a green card, US citizenship or through extended physical presence in America. The lessons are explained in detail in a 2-part blog post and will be helpful to Prince Harry who may possibly take … Continue reading Prince Harry (Part I) – Does US Citizenship Wait in the Royal Wings? What about the Impact on the Royal Family?
The Treasury Inspector General for Tax Administration (TIGTA) has been documenting some careless work being carried out by the Internal Revenue Service (IRS). We have the most recent TIGTA report (Number 2022-40-036) of May 4, 2022 reporting that the IRS destroyed 30 million “paper-filed information return documents” without bothering to process them beforehand. This destruction … Continue reading IRS Slipshod Work and Document Destruction Can Mean Big Problems – Especially for Expatriates
Join me today in a live webinar: Everything you need to know about giving up a green card or US citizenship - 2 CPE credits. Register here. The economy is not looking good with the stock market dropping sharply, with tech companies being hit most dramatically, dropping by about 40%. Crypto markets are also in … Continue reading Escaping the USA, Exit Tax and Transfer Tax Regimes: Using the “Dual National” Exception
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