Tag: US tax attorney

FORM 8938: Infinite Statute of Limitations & Everything Else You Need to Know

My prior blog post gave details about how the Form 8938, an important “Foreign Account Tax Compliance Act” (FATCA) enforcement weapon, is currently failing.  IRS enforcement efforts are soon on the upswing.  This is because the Treasury Inspector General for Tax Administration issued a report over the summer pointing out the IRS' failures with regard … Continue reading FORM 8938: Infinite Statute of Limitations & Everything Else You Need to Know →

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 →

Quicksand! US Owners of Foreign Corporations

It is usually very quick and easy to set up a foreign corporation - say, one in Belize or in the Cayman Islands.  What is not so easy is working one's way through the quagmire of required Internal Revenue Service (IRS) reporting and US  tax obligations simply because you are a US person owning shares … Continue reading Quicksand! US Owners of Foreign Corporations →

USA: One Country, Two Citizenships

One Country, Two Citizenships: John Richardson Interviews Virginia La Torre Jeker.  Most people don’t know that the US has two kinds of citizenship  – “Immigration” citizenship and “Tax” citizenship.  Tax citizenship, the monkey on your back, is hard to shake off!  Watch the interview, here.   All the US tax information you need, every week … Continue reading USA: One Country, Two Citizenships →

Married to A Non-US Spouse? Use of “Resident” Election, Filing FBAR and Form 8938

My blog post containing tax-saving tips for the filing of a US income tax return when one is married to  a non-resident alien spouse is here. It will be helpful to read that post before embarking on this one as it sets out the basics and provides the income tax rates and brackets for the 2018 … Continue reading Married to A Non-US Spouse? Use of “Resident” Election, Filing FBAR and Form 8938 →

Married to A Non-US Spouse? Tax Saving Tips For the US Income Tax Return

A US citizen or US tax resident (for example, a green card holder) who is married to a non-American when the couple lives abroad should consider certain US tax filing issues and strategies. US Tax Treatment of the Non-US Spouse When the non-US citizen spouse has obtained a green card or is otherwise treated as a … Continue reading Married to A Non-US Spouse? Tax Saving Tips For the US Income Tax Return →

All the Fun Rules — US Estate Tax for Nonresident Alien Individuals

Very few US Estate tax returns are actually filed by the estates of nonresident alien individuals. Statistics indicate that the amount of Estate Tax earned by the US Government on such returns is quite small.  The cost of structuring to avoid the tax is probably of far greater magnitude than what is collected by the US … Continue reading All the Fun Rules — US Estate Tax for Nonresident Alien Individuals →

Transfer of Property or Cash to a Foreign Corporation? FILING OF FORM 926

US persons (e.g., US citizens, US green card holders) must make an information report to the IRS when making certain transfers to foreign (non-US) corporations. Specifically, when a US person transfers (or is treated under the tax rules as having transferred) property to a foreign corporation in certain “non-recognition” transactions (e.g., a contribution of capital … Continue reading Transfer of Property or Cash to a Foreign Corporation? FILING OF FORM 926 →

Dividends from Foreign Corporations Part III – “Controlled Foreign Corporations”

Learn about the interplay between foreign corporations and eligibility for lower tax rates available only for "qualified dividends".  It's a complicated topic and all of the posts in the series should be read in order to understand the ramifications. Part I, Part II and below, Part III.  Unsurprisingly, many US owners of corporations that are … Continue reading Dividends from Foreign Corporations Part III – “Controlled Foreign Corporations” →