The U.S. is one of just two countries in the world that tax based on citizenship. (The other is Eritrea, in Africa). Taxing based on citizenship means that […]
US Expat Taxes – Who Has To File In 2022?
Category: FATCA
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” […]
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 […]
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 […]
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 […]
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. […]
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 […]
WEBINAR: Time is Running Out – OVDP Closing. FATCA Enforcement Starting.
Time is Running Out – OVDP Closing. FATCA Enforcement Starting. Come Learn at Our Free Webinar April 10th 8:00 PM – 9:00 PM GST Register here. Last month […]
Confused Yet? W-8BEN, W-8BEN-E, Foreign ITINs and Dates of Birth
Compliance with the Foreign Account Tax Compliance Act (“FATCA”) enacted 8 years ago, has resulted in a plethora of new US tax reporting requirements, forms and rules. Unfortunately, […]
Fairness? IRS Just Updated Coordination Between Streamlined Procedures and OVDP
Many of my readers will recall my earlier posts on the Streamlined Procedures and the Offshore Voluntary Disclosure Procedures (OVDP). In 2014, the IRS greatly revamped the Streamlined […]