Expatriation, Form 8854 & Fair Market Valuation of Assets – Which Date is Used?

The title of this post could also be “What a Difference a Day Makes”. Most of my readers are quite familiar with the expatriation regime, as I have written many blog posts on this topic.   Before delving into the question of the date to use when working through Form 8854, let’s have a quick review … Continue reading Expatriation, Form 8854 & Fair Market Valuation of Assets – Which Date is Used?

Social Security Benefits Paid to US and Non-US Individuals, Including Those Who Expatriated – How Are They Taxed?

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?

Foreign Assets — How Can the IRS Enforce Tax Collection Overseas? (Part II)

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)

US Passport Denied for Delinquent Tax Debt, Actual Notice to the Taxpayer Not Required

A taxpayer's US passport can be denied issuance, renewal and can even be revoked, if the taxpayer has so-called “seriously delinquent tax debt” per IRC Section 7345.  I have blogged about this before - here and here. Generally, a "seriously delinquent tax debt" is an individual's unpaid, legally enforceable federal tax debt (including interest and … Continue reading US Passport Denied for Delinquent Tax Debt, Actual Notice to the Taxpayer Not Required

US Citizenship: Do You Really Want It? Brave New World – Assisted Reproductive Technology / Surrogacy / Same-sex Marriage

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

Prince Harry (Part II) – Does US Citizenship Wait in the Royal Wings? What about the Impact on the Royal Family?

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?

Timing Considerations for Expatriation, Tax Compliance and Form 8854

I invite readers to enjoy my article, copied below, recently published by Bloomberg Tax in the Daily Tax Report.  Reproduced with permission. Published January 7, 2022. The Bureau of National Affairs, Inc. (800-372-1033) http://www.bloombergindustry.com It is online here.   My blog post today contains additional input with a link to a podcast on this topic with US … Continue reading Timing Considerations for Expatriation, Tax Compliance and Form 8854

Cannot Expatriate! US Consulate in Dubai – Joining Others Worldwide, Closes the Door on Expatriations

An alternative title for this post could be:  "Hasn't the State Department Heard About Zoom?" What’s become of the right to relinquish one’s US citizenship?  It has been thrown a curveball for the past year and a half.   Many US Embassies and Consulates throughout the world are not offering the service.  Those that did (or … Continue reading Cannot Expatriate! US Consulate in Dubai – Joining Others Worldwide, Closes the Door on Expatriations

International Taxpayers Need – But Can’t Have an IRS Online Account

An IRS online account is a safe and easy way for individual taxpayers to view specific details about their federal tax account. The American Abroad REALLY Needs an Online Tax Account How the US taxpayer living overseas would appreciate having such an online account! Time zone differences, long distance telephone charges when trying to reach … Continue reading International Taxpayers Need – But Can’t Have an IRS Online Account

Constitutionality of NIIT and Passport Revocation Rules Stand: Taxpayers Sacrificed in US Supreme Court and Tax Court  

The US Supreme Court and the Tax Court issued two big decisions impacting many US individual taxpayers. Here’s a short and not-so-sweet summary of what went down: The 3.8% Net Investment Income Tax Stands On June 17, 2021, by a clear majority vote,  the Affordable Care  (ACA) was upheld by the US Supreme Court, including … Continue reading Constitutionality of NIIT and Passport Revocation Rules Stand: Taxpayers Sacrificed in US Supreme Court and Tax Court