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
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
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
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
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
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
Are you concerned about the high IRS tax rates on a foreign trust? It is important to understand the tax and reporting consequences on this specific type of investment. It may very well be time to evaluate the net value of...more
On September 8, 2023, the IRS issued a News Release suggesting that FBAR compliance investigations and audits would heat up in the near future. For those unfamiliar with FBARs, federal law requires United States persons to...more
On September 8, 2023, the IRS announced a multitude of compliance initiatives aimed at high-income taxpayers, partnerships, digital assets, FBARs and labor brokers. According to the announcement, the IRS has finalized its...more
We continue with Part 2 – International Tax Primer for US Taxpayers and Expatriates with one of the most common forms associated with foreign asset and income reporting to the IRS: Form 8938, the Statement of Specified...more
Welcome to part 1 of our Allen Barron International Tax Primer for US Taxpayers and Expatriates. The United States is one of the few countries in the world that taxes its citizens on their worldwide income. US taxpayers are...more
Taxpayers recently won a significant victory at the Supreme Court in a penalty case involving a non-willful failure to file a Report of Foreign Bank and Financial Accounts (“FBAR”) under the Bank Secrecy Act (the “BSA”)....more
After years of litigation, the United States Supreme Court, in Bittner v. United States, 598 U.S. ____ (2023), determined that the penalty for a non-willful failure to file a Report of Foreign Bank and Financial Accounts...more
Taxpayers who hold foreign accounts finally received clarity as the Supreme Court ruled that the $10,000 non-willful penalty for failure to file a FinCEN Form 114, Report of Foreign Bank and Financial Accounts (FBAR) applies...more
If you have unreported foreign accounts, you are not alone. Every year, I speak with hundreds of clients with tax non-reporting issues (e.g., FBARs, Form 8938, Form 3520, Form 3520-A, etc.). The good news: the IRS offers...more
Muchos ciudadanos americanos que viven en el extranjero no presentan su declaración de impuestos en Estados Unidos de América (“EUA”) por diversas cuestiones. Generalmente, esto sucede porque se tiene la creencia que no es...more
Why You Should Hire a Tax Professional to Review Your Foreign Legal Structure - U.S. parented corporations that have foreign operations conducted through a foreign legal structure have significant U.S. tax filing and...more
The Bank Secrecy Act (“BSA”) requires United States persons (“USPs”) to file FinCEN Forms 114, Report of Foreign Bank and Financial Accounts (“FBARs”), for each calendar year in which the aggregate amount(s) in certain...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of October 3, 2022 – October 7, 2022...more