US Tax Inflation Adjustments for 2023 – Impact on the International Family

Certain provisions in the United States Internal Revenue Code (Code) are tied to inflation to prevent rising prices from resulting in higher taxes. Annual inflation adjustments have been part of the tax rules for well over 2 decades. These formulas set by Congress help prevent inflation from nudging taxpayers into higher tax brackets and increasing … Continue reading US Tax Inflation Adjustments for 2023 – Impact on the International Family →

Foreign Loans & Mortgages – Foreigners Residing in US / Expats Returning to US…. Surprise! US Withholding Tax Required on Interest Payments?

Many Americans living abroad purchase properties in their foreign country of residence. They often accomplish this with financing from a financial institution located in the country where the property was purchased. Later, they may return to the US and continue holding the property and meeting their mortgage payments. Similarly, many non-US citizens purchase properties with … Continue reading Foreign Loans & Mortgages – Foreigners Residing in US / Expats Returning to US…. Surprise! US Withholding Tax Required on Interest Payments? →

Determinative Factors: “Debt” v. “Equity” and Your Loan to a Foreign Corporation (Part II)

My recent blog post, here examined some of the tax consequences that could occur when a taxpayer mistakenly classifies an advance to a foreign corporation as a “loan” but that the Internal Revenue Service (IRS) treats as a stockholding interest (“equity”) in the corporation. Last week’s blog post began examining factors used by the courts … Continue reading Determinative Factors: “Debt” v. “Equity” and Your Loan to a Foreign Corporation (Part II) →

Looking for Mr. FBAR: FBAR Filings for Trustees, Beneficiaries & Trust Grantors

My earlier post set out certain details about the responsibility for a trust to file the Report of Foreign Financial Accounts (Form 114), or FBAR, with respect to foreign accounts it owns or is deemed to own under the FBAR rules. Today’s discussion covers the situation when trustees, trust beneficiaries and grantors (i.e., the trust … Continue reading Looking for Mr. FBAR: FBAR Filings for Trustees, Beneficiaries & Trust Grantors →

UAE Federal Corporate Tax: How Will it Impact the US Taxpayer? Part II

As discussed in my prior blog post, full details here, on January 31, the United Arab Emirates (UAE) Ministry of Finance announced the introduction of a federal corporate tax (CT) on business, to be implemented in June 2023. The UAE is joining the other Gulf Cooperation Council countries (with exception for Bahrain) that collect tax … Continue reading UAE Federal Corporate Tax: How Will it Impact the US Taxpayer? Part II →

UAE Federal Corporate Tax: How Will it Impact the US Taxpayer? Part I

My most recent article, co-authored with Clarence Ellis and published by Bloomberg, is copied in full below. The article examines in unique detail the latest news in the tax world of the United Arab Emirates (UAE), which announced it will start to impose tax on business enterprises in the Emirates. Before you read the full … Continue reading UAE Federal Corporate Tax: How Will it Impact the US Taxpayer? Part I →