Law School Toolbox Podcast Episode 263: Listen and Learn -- Subject Matter Jurisdiction
You may recall that earlier this year the IRS launched an initiative to pursue 125,000 “high-income, high-wealth” taxpayers who have not filed taxes since 2017. These were cases where the IRS received third party information...more
Over the last couple of years, several of my friends have become citizens of the country from which their parents emigrated to the U.S. Also during that period, some acquaintances took advantage of the so-called “golden...more
Ever thought about packing it all up and starting that romantic, expatriate life abroad? Ever felt like these parts were just so wild, it was time to find yourself a new passport? Expatriation, where a US citizen renounces...more
The United States government has four primary whistleblower statutes and reward programs: •The Federal False Claims Act (“FCA”)- •The Securities and Exchange Commission (“SEC”) Whistleblower Program- •The Internal...more
Ever since the advent of FATCA and related global tax transparency movements, U.S. individuals living abroad have likely become far too acquainted with the challenges posed by holding U.S. citizenship or residency. Perhaps...more
On September 6, 2019, IRS announced Relief Procedures for Certain Former Citizens. These are procedures for certain persons who have relinquished, or intend to relinquish, their United States citizenship, who wish to come...more
On September 6, 2019, the Internal Revenue Service (IRS) announced the new “Relief Procedures for Certain Former Citizens” (IRS Relief Procedures) who relinquished their United States (U.S.) Citizenship after March 18, 2010....more
On September 6, 2019, the IRS announced procedures for certain persons who have relinquished, or intend to relinquish, their U.S. citizenship and who wish to come into compliance with their U.S. income tax and reporting...more
Outlook for This Week in the Nation's Capital - Congress. After some very contentious debate and a handful of defections, the House late last week passed the annual National Defense Authorization Act on a rare party line...more
Living abroad can be a wonderful opportunity for many U.S. Persons, but a few commonly misunderstood aspects of the U.S. tax system directly impact such “expats,” often to their financial detriment. Here are the five most...more
There are Individuals out there that are US Citizens (“Americans”) and they are not aware of it. Under US Tax Law, these individuals have US tax reporting responsibilities and tax obligations. These Individuals are known as...more
A significant number of US Taxpayers living overseas have become “unbankable” where they live because of high account servicing costs for local banks (Foreign Financial Institutions – also known as FFIs) caused by the...more
NUMBER OF THE WEEK: 3,415. The number of people who renounced their citizenship in 2014 according to IRS data. This is one of the five highest totals on record since the U.S. Congress passed the Foreign Account Tax Compliance...more
The question of who is a U.S. person has always been relevant for tax purposes because it determines who is subject to (a) U.S. income, gift and estate tax, (b) filing Foreign Bank Account Reports (FBARs), and (c) the ‘‘exit...more
The United States is one of the few countries to tax the worldwide-earned income of its citizens and permanent residents. Millions of American citizens residing outside the U.S. have no direct ties to their home country since...more