Fear Factors: Dual Nationals and the IRS


What do the recent G20 discussions and the IRS’ enforcement of foreign asset reporting have in common and why should “dual nationals” be concerned? First, a brief definition for purposes of this article. A “dual national” is an individual who has income tax reporting requirements in two or more countries. Such a person includes individuals in the U.S. on work Visas, Green Card holders and individuals who are citizens of the U.S. and another country (by birth, as an example). I am not, in this discussion, including corporate or other business interests in this definition.

According to published reports from the G20 meeting, a total of $14bn in unpaid tax has recently been collected by seven of the G20 members from about 100,000 individuals worldwide from hidden assets (bank accounts) estimated to be worth in excess of $120bn. There remain, according to some estimates, in excess of $1tn in hidden untaxed assets globally. Since 2009 the IRS has offered two voluntary disclosure programs to get U.S. taxpayers to report foreign held financial accounts, the most recent program was the 2011 Offshore Voluntary Disclosure Initiative (OVDI). Many of the participants in the two IRS programs were “dual nationals”, but many more did not enter either program. However, some “dual nationals” are now being forced to come forward because of actions being taken by offshore financial institutions.

Please see full article below for more information.

LOADING PDF: If there are any problems, click here to download the file.

Written by:

Published In:


DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

© Sanford Millar, Law Offices of Sanford I. Millar | Attorney Advertising

Don't miss a thing! Build a custom news brief:

Read fresh new writing on compliance, cybersecurity, Dodd-Frank, whistleblowers, social media, hiring & firing, patent reform, the NLRB, Obamacare, the SEC…

…or whatever matters the most to you. Follow authors, firms, and topics on JD Supra.

Create your news brief now - it's free and easy »


Sanford Millar
Law Offices of Sanford I. Millar

Experience and Qualifications: Over 30 years of experience in domestic and international tax... View Profile »

Follow Law Offices of Sanford I. Millar:

Reporters on Deadline

All the intelligence you need, in one easy email:

Great! Your first step to building an email digest of JD Supra authors and topics. Log in with LinkedIn so we can start sending your digest...

Sign up for your custom alerts now, using LinkedIn ›

* With LinkedIn, you don't need to create a separate login to manage your free JD Supra account, and we can make suggestions based on your needs and interests. We will not post anything on LinkedIn in your name.