What does the substantial recent reduction in the IRS mean for U.S. taxpayers and expatriates? How will staff reductions affect the agency’s ability to audit and collect taxes owed by U.S. taxpayers around the world? What...more
Why do you need an experienced tax attorney when tax issues strike? What do you need to know about communications with the IRS and California's tax agencies?...more
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
Earlier this year the U.S. Department of Justice (“DOJ”) brought USA v. Ahlgren, its first crypto case with tax evasion allegations unrelated to another crime, demonstrating the DOJ’s willingness to pursue stand-alone crypto...more
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
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
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
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
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
The National Taxpayer Advocate Report for 2017 (Purple Book) is a summary of legislative recommendations that the Office of Taxpayer Advocate (OTA) believes will strengthen taxpayers rights and improve tax administration. ...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
Thinking about giving up your US citizenship pending the results of the Presidential election in November 2016? Concerned because you have been an “Expat” for a long time and have not filed US Tax returns? Just realized that...more
As discussed in a prior post, the U.S. Internal Revenue Service (“IRS”) is currently in the process of finalizing its regulations implementing the Affordable Care Act’s (“ACA”) “Employer Mandate.” The Employer Mandate, which...more