US Expatriate Tax Planning - Part 2 - A Podcast with Janathan Allen
US Expatriate Tax Planning - Part 1 - A Podcast with Janathan Allen
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
For years, FBAR litigants have made the commonsense argument that large willful FBAR penalties, which can exceed the value of the unreported foreign accounts themselves, violate the excessive fines clause of the Eighth...more
On 10/12/23, the IRS announced new tax gap projections for tax years 2020 and 2021 showing the projected gross tax gap increased to $688 billion in tax year 2021, a rise of more than $192 billion from the prior estimates for...more
The National Taxpayer Advocate 2023 Annual Report to Congress highlights how Taxpayers abroad are underserved and continue to face challenges in meeting their U.S. tax obligations. As a result, the National Taxpayer Advocate...more
In US Expatriate Tax Planning – Part 2, Ms. Allen picks up the conversation regarding tax and legal issue U.S. expatriates might face. The discussion turns to real estate matters, and the issue of moving money from the United...more
How does the IRS define willfulness in unreported or under-reported offshore income? What actions help determine whether a U.S. taxpayer's actions amount to "willful or non-willful" conduct? Why should U.S. taxpayers be...more
Many Americans have not noticed the paragraph above their signature line on the 1040 and other IRS and state tax forms, which notifies the taxpayer that they signed their tax return "under the penalties of perjury" and that...more
What is an FBAR, and what information is a U.S. taxpayer required to report to the U.S. Government and the IRS? There are many questions about the requirements for U.S. taxpayers with foreign accounts, investments, and...more
Are you thinking of moving to another country? Over the past decade, a record number of U.S. citizens have decided to live and work abroad. There are many issues you may not have considered that will impact any decision to...more
Are you wondering when a US taxpayer should consider the IRS Voluntary Disclosure Program or VDP? Are you concerned about unreported or under-reported income, financial accounts, assets, investments, cryptocurrency or...more
What do you need to know about the IRS updated Streamlined Filing Compliance Procedures or "Streamlined Procedures?" Are you concerned about unreported or under-reported offshore income or assets? Are there accounts you...more
Many US taxpayers still have questions regarding offshore accounts and FBAR filing requirements and compliance. Is there a genuine risk their activities (or lack of compliance) will come to light? The definition of a US...more
What are the risks of an IRS quiet disclosure? Is there a formal IRS process known as a "quiet disclosure," and does the IRS honor this strategy for amended tax returns?...more
Cryptocurrency has revolutionized the financial markets but also created tax traps for the unwary investor. Building on proposed regulations issued last year, the IRS recently increased its oversight of cryptocurrency...more
When is a US Taxpayer required to disclose offshore accounts on an FBAR and IRS Form 8938? While many US taxpayers and expatriates have come to understand the requirements of the FinCEN Form 114 or FBAR, a surprising number...more
In the US Expatriate Tax Planning podcast, Janathan Allen discusses important tax issues from the perspective of a US Expatriate. One of the first and most important thing to know for any US taxpayer is the United States...more
It is common for a US taxpayer to ask “what happens if you don’t file an FBAR or a Form 8938, Statement of Specified Foreign Assets with the IRS? Why do I have to worry about filing an FBAR in San Diego or anywhere in the US,...more
What are the IRS streamlined filing compliance procedures (known more commonly as the “streamlined procedures”), and when should a US taxpayer consider the IRS streamlined procedures to come into compliance with IRS reporting...more
US tax filing is underway, and as we approach the April 15 deadline we would like to offer additional tax updates and information for US expatriates. The first and most important thing for US expatriates to know about taxes...more
For many organizations and individuals, the end of the calendar year generates significant reporting obligations, particularly with respect to the Internal Revenue Service. The following requirements may not be obvious, but...more
Could Artificial Intelligence (AI) increase the likelihood of an IRS audit in your future? How does the IRS use AI to identify US taxpayers who attempt to hide assets, under-report income or otherwise cheat the IRS? In...more
In 2009, the IRS created its Global High Wealth Industry Group, known more familiarly as the “Wealth Squad.” This group starts with an examination of a “key case,” which is typically a wealthy person’s individual tax return,...more
Are there strategies to avoid an IRS audit? What are some of the known risks for triggering an IRS audit? What should you do if you have are concerned about the information provided a previous tax return? Is there a way to...more
En 9/8/23, el IRS anunció nuevos esfuerzos de cumplimiento que se centrarán en aumentar el escrutinio de los contribuyentes de altos ingresos/altos patrimonios, sociedades, corporaciones y promotores que abusan de las normas...more
What are the most important elements of estate and tax planning for US expatriates? Are you planning to move out of the United States? Are you a US taxpayer who lives and works outside of the country? What are some of the...more