US Expatriate Tax Planning - Part 2 - A Podcast with Janathan Allen
US Expatriate Tax Planning - Part 1 - A Podcast with Janathan Allen
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
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
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
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
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
Under current FinCEN regulations, a foreign account holding virtual currency is not reportable on the FBAR. However, FinCEN in its FinCEN Notice 2020-2, proposes amending reports of foreign financial accounts (FBAR)...more
On May 30, 2018, the AICPA (American Institute of Certified Public Accountants) wrote a letter to the IRS to obtain further definition and clarity regarding Virtual Currency (VC) FATCA and FBAR reporting requirements....more
There are legal and financial consequences to any U.S. person who underreports their income. Moreover, similar consequences may exist even in a situation in which all income is reported, yet certain information returns are...more
On March 13th, the Internal Revenue Service ("IRS") announced that the offshore voluntary disclosure program ("OVDP"), which was first launched in 2009 and modified several times, will close to new taxpayers after September...more
Investment advisers registered with the U.S. Securities and Exchange Commission (“SEC”) or with a state (“Advisers”) as well as commodity pool operators (“CPOs”) and commodity trading advisors (“CTAs”) registered with the...more
In this first of (we hope) many posts on the interesting and myriad tax issues arising in the world of cryptocurrency and blockchain technology, we focus on the very basic U.S. federal income tax consequences of...more
Federal law requires U.S. citizens and resident aliens to report world-wide income, including income from foreign trusts, bank and securities accounts. In addition to attaching Schedule B to their tax returns disclosing...more
All U.S. citizens and permanent residents are required to annually file a U.S. income tax return reporting their worldwide income from all sources. Additionally, U.S. citizens and permanent who have an interest in or...more
Maintaining a foreign bank or other financial account is not illegal. Such accounts are increasingly common, as the globe shrinks. However, in the case of U.S. citizens or residents (and certain non-residents), failing to...more
Action Item: This is the fifth installment of our Annual Estate Planning Newsletter, and focuses on foreign matters. We urge you to review this installment to ensure that your 2016 estate and tax planning is in order. ...more
The annual deadline for filing FinCEN Form 114, Report of Foreign Bank and Financial Accounts (commonly known as the “FBAR” form), is fast-approaching. Any U.S. taxpayer with a financial interest in, or signature or other...more
In 2010, the U.S. enacted a sweeping change in enforcement of its tax laws on foreign financial interests, the Foreign Account Tax Compliance Act (FATCA). The main thrust of the act is to penalize foreign financial...more
Now that the election is over, we anticipate having some guidance soon with respect to the numerous tax and planning issues that have been mired in uncertainty for the past two years. Many tax benefits are scheduled to...more
Since the G-20 meeting on April 2, 2009, there has been a worldwide emphasis on the elimination of bank secrecy through the implementation of tax information exchange agreements ("TIEA") with countries or jurisdictions that...more