News & Analysis as of

Internal Revenue Code (IRC) Expatriates

Allen Barron, Inc.

A New Wave of U.S. Expatriate Income Tax Refund Applications?...

Allen Barron, Inc. on

Is a new wave of U.S. expatriate income tax refund applications on the table? The answer to this question hangs in the balance as we await an appeal on the question of whether or not specific Foreign Tax Credits can be...more

Bilzin Sumberg

Inflation Adjustments for 2024: Key Information for International Private Client Practitioners

Bilzin Sumberg on

The IRS recently released its inflation adjustments for 2024. International private client practitioners should note the following: US Estate and Gift Tax Exclusion Amount: $13,610,000 (up from $12,920,000)...more

Holland & Knight LLP

TIGTA Tasks IRS with Enhanced Enforcement of Noncompliant Expatriates

Holland & Knight LLP on

The U.S. Treasury Inspector General for Tax Administration (TIGTA) recently audited the Internal Revenue Service's (IRS) programs to ensure compliance by expatriates with the provisions under Sections 877 and 877A of the...more

Holland & Knight LLP

New IRS Procedure Provides Favorable Path for Non-Compliant Expatriates to Become Tax Compliant

Holland & Knight LLP on

In the "Relief Procedures for Certain Former Citizens" and accompanying FAQs, the Internal Revenue Service (IRS) provides a simplified pathway for certain non-compliant U.S. citizens who expatriated after March 18, 2010, to...more

Foodman CPAs & Advisors

Watch out if you are an Expatriate US Passport Holder with Tax Debt and receive Notice CP-508C!

According to the US Department of State, there are approximately nine (9) Million US passport holders living overseas. There continues to be a misimpression by certain US Taxpayers living overseas that they are not required...more

Butler Snow LLP

Way, Way Back: Retroactivity in the Proposed 2801 Regulations

Butler Snow LLP on

Individuals who relinquished U.S. citizenship since 2008 may find themselves with U.S. tax exposure for gifts they made before they expatriated under proposed regulations announced by the IRS. Under the current expatriation...more

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