US Expatriate Tax Planning - Part 2 - A Podcast with Janathan Allen
US Expatriate Tax Planning - Part 1 - A Podcast with Janathan Allen
This article is the second in a series analyzing the proposed Taxpayer Assistance and Service Act (the “TAS Act”), bipartisan legislation introduced by Senators Crapo and Wyden to improve service and administration at the...more
Should you amend an error in a previous IRS tax filing or just let it go and hope the agency doesn't notice? We are a few weeks from the annual deadline for most U.S. taxpayers to file tax returns, and it may surprise you to...more
For many foreign nationals living and working in California and across the United States, the complexity of U.S. tax laws often becomes clear only when an IRS notice arrives in the mail. Navigating the complexities and...more
The IRS' Criminal Investigation Voluntary Disclosure Practice (VDP) has long served as the principal pathway for taxpayers with potential criminal tax exposure to self-correct their past noncompliance and pay outstanding tax...more
On February 26, 2026, the Senate Finance Committee Chairman Mike Crapo (R-Idaho) and Ranking Member Ron Wyden (D-Oregon) introduced the Taxpayer Assistance and Service Act (TAS) to the Senate Floor with bipartisan support....more
There are substantial challenges for U.S. taxpayers, expatriates, and foreign nationals and spouses who live and work in the United States, with offshore accounts, assets, investments, business interests, or income. Many were...more
Foreign nationals living and working in California—particularly in cities like San Diego, Los Angeles, San Francisco, and San Jose (Silicon Valley)—are often surprised by how quickly U.S. tax obligations can apply. Whether...more
Cross‑border marriages are becoming increasingly common, and so are the estate planning surprises that come with them. If at least one spouse is not a U.S. citizen, familiar tools like the unlimited marital deduction and...more
A request for public comment reveals the IRS is considering updates to the Voluntary Disclosure practice. The agency states its “commitment to improve its processes, and to further incentivize non-compliant taxpayers to come...more
Enforcing foreign bank account reporting requirements through penalties has been an IRS priority for several years, spawning numerous precedent-setting cases throughout the courts. In the latest such case[1], a federal...more
How might marrying a non-US citizen affect your taxes? What are some of the hidden issues that the IRS, California, and other state tax agencies may raise in an audit?...more
Did you just find out that as a dual citizen you have to report U.S. taxes even if you live abroad? Did you just discover you needed an FBAR, Form 5471, GILTI calculation, Form 3520, Form 5472, or other foreign reporting?...more
What are your FBAR requirements as a U.S. person or taxpayer for an offshore account, group of accounts, property, or investment? The penalties for non-compliance with reporting offshore accounts, assets, and income are...more
A district court in Texas has dismissed a lawsuit filed by the Justice Department to collect an FBAR penalty, concluding for the first time that the Internal Revenue Service’s administrative assessment of an FBAR penalty...more
It’s no secret that spouses, particularly in bad times, may hide things from one another. In fact, there are bodies of cases involving such marital behavior. However, we’ve gotten another recent reminder that such attempts...more
High-net-worth individuals and families contemplating diversifying their wealth beyond U.S. borders, also known as outbound wealth planning, may be motivated by concerns about domestic political developments, economic policy...more
What happens if you are accused by the IRS, the FTB, or another California tax agency regarding omissions, fraud, or false information on a tax return? The short answer is simple: failure to make a full, transparent, and...more
What do you need to know about the IRS and state tax complications of offshore investments? It is common to have international investments in your portfolio, not to mention business interests. How do you navigate the...more
How many U.S. taxpayers and expatriates may need to file offshore disclosures and FBARs with the IRS? Should those who have not yet filed a disclosure application utilize the VDP (Voluntary Disclosure Program) or a...more
One of the most important indications of when you need a tax attorney is any dispute with or contact from the IRS or any California tax agency. This is especially true if the matter involves an audit (or questions regarding...more
The world is an ever-changing, ever-evolving crucible of financial and other serious challenges for expats and those considering moving abroad, as well as foreign nationals living and working in the United States. Oversight,...more
In its recent decision in United States v. Leeds, the United States District Court for the District of Idaho upheld the application of willful penalties against a deceased husband for failing to report certain foreign bank...more
International business and offshore investment and banking create genuine risk and exposure with the IRS. This extends to real estate ownership outside of the U.S. and other offshore-related financial activities, which raise...more
A well-structured trust is often a central estate planning tool for small businesses and closely held family business owners when passing a business or wealth to your children. This includes heirs, beneficiaries, and future...more
A common strategy many wealth management firms recommend is ensuring that as much as 30% of your portfolio includes foreign investments and securities. What is the potential tax impact of foreign investments? One of the keys...more