US Expatriate Tax Planning - Part 2 - A Podcast with Janathan Allen
US Expatriate Tax Planning - Part 1 - A Podcast with Janathan Allen
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 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
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
The IRS has clearly identified legitimate reasons why "U.S. Persons" would establish or maintain ownership in a foreign trust. However, a foreign trust creates complex IRS reporting requirements for US taxpayers who own a...more
What is willful blindness according to the IRS? How is this important in tax cases involving unreported or under-reported income, disclosure of offshore assets and income, FinCEN Form 114 (more commonly referred to as an...more
Americans who live abroad continue to be subject to U.S. taxation despite having left the United States. American expats should be aware of this and the consequences of not being tax compliant. George McCormick discusses...more
Conflicting Decisions: In August, the U.S. Court of Appeals for the Eleventh Circuit held in United States v. Schwarzbaum that a monetary civil penalty imposed for willfully failing to file a foreign bank account report...more
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
For years, FBAR litigants have made the commonsense argument that large willful FBAR penalties, which can exceed the value of the unreported foreign accounts themselves, violate the excessive fines clause of the Eighth...more
In US Expatriate Tax Planning – Part 2, Ms. Allen picks up the conversation regarding tax and legal issue U.S. expatriates might face. The discussion turns to real estate matters, and the issue of moving money from the United...more
How does the IRS define willfulness in unreported or under-reported offshore income? What actions help determine whether a U.S. taxpayer's actions amount to "willful or non-willful" conduct? Why should U.S. taxpayers be...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
What are the risks of an IRS quiet disclosure? Is there a formal IRS process known as a "quiet disclosure," and does the IRS honor this strategy for amended tax returns?...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
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
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
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
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