The Curious Tax Case of Accidental Americans
In general, the United States government is adept at primarily imposing its laws and policies on those who live in the country or are otherwise closely associated with the goings-on of the country. This is, of course, as it should be – despite the occasional propensity of the government to stick its nose where it […]
FATCA Back in the News
That pestilent FATCA law is back in the news again. Back on July 9, 2018, the Treasury Inspector General for Tax Administration (TIGTA) issued a report (July TIGTA Report) highlighting the IRS’ shortcomings in enforcing FATCA. For those unfamiliar with FATCA, it stands for “Foreign Account Tax Compliance Act.” Sometimes referred to derisively by the nickname […]
The Weighty Burden of the Full FBAR Penalty
No one likes paying the IRS as it is, let alone being ordered to pay 50% of the assets kept in overseas bank accounts as a penalty for failing to file a Report of Foreign Bank and Financial Account, or FBAR, but that’s exactly what happened to Mindy P. Norman. In October 2013, Ms. Norman was […]
Lessons Learned from Manafort Conviction that Every Taxpayer Should Know
The conviction of former Trump campaign chairman Paul Manafort on eight counts of financial crimes marks the first trial victory of Special Counsel Robert Mueller’s probing investigation into President Trump’s associates. After four days of deliberating, the jury found Manafort guilty of five counts of filing false tax returns on tens of millions of dollars […]
FATCA, the IRS, and You: The Importance of Reporting
If you have offshore bank accounts, the reality of FATCA should be less mystery and more common knowledge. Short for the Foreign Account Tax Compliance Act, FATCA is the legislation behind the government’s ability to find your funds anywhere in the world and, subsequently, bring down punitive actions against those not following the rules. Bottom line? If […]
How to Deal With A Dreaded FATCA Letter From Your Foreign Bank
Have accounts overseas? Think they’re hidden from the U.S. government? Think again. As many Americans with foreign bank accounts are startled to discover, the U.S. government can and will find your bank accounts and use information from your bank to confirm your compliance with U.S. tax law. From millions in the bank to a few dollars sitting […]
Is U.S. Citizenship-Based Taxation On Its Way Out?
The prayers of Americans living overseas may have finally been answered. A bill is in the works in the United States Congress to establish “Territorial Taxation for Individuals” (TTFI). If passed, the bill would change the current tax regime from one of “U.S. citizenship-based taxation” to “residence-based taxation.” This would go a long way to […]
A Message from Uncle Sam to Taxpayers with Foreign Assets: Don’t Forget Your U.S. Tax Obligations
On April 9, 2018, the IRS published a press release entitled, “IRS reminds those with foreign assets about U.S. tax obligations.” In this podcast, I highlight some of the key points emphasized by the IRS for those with foreign assets.
Big Win for Taxpayers in A Watershed “Willful” FBAR Penalty Case
I’m a little slow in getting around to this one, but back on September 20, 2017, the Eastern District of Pennsylvania released a taxpayer-friendly opinion regarding the “willfulness” standard in FBAR penalty cases. In Bedrosian v. United States, Case No. 2:15-cv-05853-MMB (E.D. Pa., Sept. 20, 2017), the district court held that the government had not met its burden of proof […]
Owe More Than $ 50,000 to the IRS? You May Be Risking More Than Just a Good Night’s Sleep …
Hold on to your horses. The IRS recently adopted new procedures required under a 2015 law designed to clamp down on taxpayers with “seriously delinquent tax debts.” On January 16, 2018, the IRS issued Notice 2018-1, which has all of the bite of the execution of “Order 66,” an order implanted into the clones by the […]