United States tax matters can be confusing to even the most seasoned American expat. In addition, although they may not realize it, foreign persons with US connections may also be impacted by US tax issues. Many non-US persons have a connection to the USA in some manner. Perhaps a family member is married to a US person; perhaps a family member has been studying in the US and may decide to remain there or to get a green card. Other connections can exist such as the desire to purchase US real property as an investment or a vacation home; or a desire to invest in the US securities market; maybe the family has a business which is now taking on US connections, for example, by selling goods or providing services into the US. In any such instance, US tax issues must be considered and planned for.
Can You Claim a Refund of Your “Willful” FBAR Penalty?
We had a very interesting case decided May 16 2018 when a district court in Texas granted Dominique Colliot’s motion for summary judgment (United States, v. Dominique G. […]
Foreign Individuals: No Help From US Estate Tax Reform (Part I)
Prior to the actual passage of the “Tax Cuts and Jobs Act” (TCJA) on December 22 2017, there were some high expectations that the disparity in the US […]
Expatriate’s Foreign Housing Exclusion – Being Chipped Away
Overview A foreign housing exclusion is available for certain overseas housing expenses that exceed a “base housing amount”. Self-employed persons cannot claim the foreign housing exclusion. Self-employed taxpayers […]
Consequences of Involving an American in Your Non-US business
Most people would never imagine that having an American business partner or employee (or even an American spouse) could result in having to disclose their business’ finances to […]
OOOPS! I Created a Foreign Trust (Part II)
Part I of this blog post set out the tax problems that arise when one has created a foreign trust with US beneficiaries. This Part II will probe […]
OOOPS! I Created a Foreign Trust (Part I)
Often, persons living abroad are asked to help care for an elderly parent who lives in the USA. Similar situations can arise for other family members, some of […]
Courts Serve Deadly FBAR Cocktail: Easier IRS “Willful” Penalty Win
There has been debate as to the “burden of proof” that must be met by the Internal Revenue Service (IRS) in asserting that an FBAR violation was “willful”. […]
Audits: IRS is Fudging the Numbers!
The Internal Revenue Service (IRS) looks at taxpayers under audit with a jaundiced eye, often questioning their numbers. Well, talk about the “pot calling the kettle black”! The […]
Calculating the Transition Tax: Just Like Dental Work – Painful in More Ways Than One
Most readers have some familiarity by now with new Internal Revenue Code Section 965 and the “deemed repatriation” or “transition tax” introduced by the Tax Cuts and Jobs Act […]