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Tax Primer for US Expats and Foreigners

All the tax information you need is readily available for free in Virginia’s Tax Primer for US Expats and Foreigners.  The Primer covers numerous topics that are most relevant […]

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The Sky’s the Limit: FBAR Penalty Win for IRS – Recent 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” […]

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Court Slams IRS: Can’t Assess More Than $100,000 “Willful” FBAR Penalty

The Internal Revenue Service (IRS) must be fuming over the recent court decision in United States v. Colliot (W.D. Texas, Austin Division, Case No. AU-16-CA-01281-SS).  The case was initiated by […]

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FBAR “Willful” Penalty: Recent Case, Taxpayer “Charged With Knowledge”

I blogged recently about the fact that mounting court cases have given the stamp of approval for the Government to meet a lower “burden of proof” in demonstrating […]

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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. […]

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Americans Abroad – May Legislative Relief Be Forthcoming?

I have blogged extensively about the US tax problems faced by Americans living and working overseas (for example, see my posts here, here and here). There is a […]

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Passport Revocation Update: Over 436,000 Taxpayers Meet “Certification” Criteria

Many of my readers already know that one’s US passport is in serious jeopardy if a taxpayer has what is called “seriously delinquent tax debt”.  First, some brief […]

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Form 1040: Similar to a Postcard, But …With (LONG) Letters Attached

Looks to me like the Internal Revenue Service (IRS) is doing the “shuffle”!  The new version of Form 1040 for 2018 certainly looks shorter, but closer inspection shows […]

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US Tax Perils of International Community Property

US tax liabilities and requirements to file US tax and information returns are impacted by community property laws that exist in many foreign countries across the globe.  Today’s […]

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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 […]

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

This tax filing season brought a wave of questions about Form 5472.  Interest in this complex form was renewed because of recent Treasury Regulations requiring that it be […]

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Newest IRS Campaigns – Targeting All Things Foreign, Especially NRAs

  For the past few years, the Internal Revenue Service’s (IRS) Large Business and International (LB&I) Division has been shifting to a new audit strategy known as “campaigns.” […]

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Foreign Individuals: No Help From US Estate Tax Reform (Part II)

Part I of this blog post examined some of the rules regarding the US estate tax and how it applies to non-US persons (noncitizen/nonresident). Unfortunately the US estate […]

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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. […]

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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 […]

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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 […]

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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 […]

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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 […]

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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 […]

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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”.  […]

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