MORE Real Life Examples: US Tax Traps of International Community Property

Part I of my blog post explained the basics of community property and how US tax laws can override certain community property principles when a US/NRA married couple is involved. This was followed by a blog post posing a smattering of real-life examples that demonstrated how community property laws can impact the US tax situation … Continue reading MORE Real Life Examples: US Tax Traps of International Community Property →

OVDP Ending / IRS To Announce New Procedures

The Internal Revenue Service (IRS) reminded taxpayers yesterday that they have until September 28 to apply for the Offshore Voluntary Disclosure Program (OVDP). In March, the IRS announced the program would end on the 28th of this month. The IRS has made clear that it will continue to hold taxpayers with undisclosed offshore holdings accountable after … Continue reading OVDP Ending / IRS To Announce New Procedures →

Katholos – New Case Shows IRS Aggression in Asserting FBAR “Willful” Penalty

I have been blogging recently (here and here) about the IRS’ aggressive stance in determining what constitutes a taxpayer’s “willful” failure to file an FBAR and the fact that mounting court cases show the judiciary is buying in to the IRS’ position. Courts appear to be more easily upholding a finding of “willfulness” when it … Continue reading Katholos – New Case Shows IRS Aggression in Asserting FBAR “Willful” Penalty →

Flying Under the Radar: Personal Use of “Business” Frequent Flyer Miles

Do I have to pay tax on that? Get the full scoop in today's post! “Expat” taxpayers living abroad are often given certain perks from their employers that would not be provided if the individual remained State-side. For example, provision by the employer for airline tickets home for the taxpayer and his/her family; or payment … Continue reading Flying Under the Radar: Personal Use of “Business” Frequent Flyer Miles →

The Sky’s the Limit: FBAR Penalty Win for IRS – New Case Upholds 50% of Account Balance

I have been keeping readers up to date with the current controversy surrounding imposition of an FBAR penalty for “willful” violations. Two courts have limited the FBAR “willfulness” penalty to $100,000 because the Department of Treasury did not update the relevant regulations to match the statute as revised by Congress in 2004. Essentially the dispute … Continue reading The Sky’s the Limit: FBAR Penalty Win for IRS – New Case Upholds 50% of Account Balance →

The J5 International Tax Hunt is On….

Many countries are waking up to the fact that offshore structures, financial instruments, cryptocurrency and other advances in technology, when inappropriately used, are fast outwitting their tax collectors. This wake-up was eventually accompanied by the realization that there is more power in collaboration and in numbers. Who or What is the “J5”? The “Organization for … Continue reading The J5 International Tax Hunt is On…. →

Form 5472 – Everything You Need To Know (Part II)

Last week’s blog post covered some basics about Form 5472, including how the Form helps the US Internal Revenue Service (IRS) learn about foreign-owned businesses in the US and when to audit them, the meanings of certain terms such as what is meant by a “reportable transaction” with a “related party”, and the situation requiring filing of … Continue reading Form 5472 – Everything You Need To Know (Part II) →