In our blog from back at the end of December of 2015, we discussed a newly-enacted Code Section 7345 of the Internal Revenue Code, which authorizes the denial, revocation, or limiting of a delinquent…
Read MoreIn a very recent decision (Maze v. IRS), the D.C. Circuit Court of Appeals upheld a lower court decision blocking several taxpayers’ efforts to leave the OVDP tax amnesty program and enter the…
Read MoreAccording to Treasury Department numbers, 2016 broke the record for annual U.S. citizenship renunciations with a grand total of 5,411 renunciations. As we’ve noted previously, possible reasons for…
Read MoreThe importance of income tax treaties should not be underestimated when considering the U.S. tax implications of living abroad. U.S. and foreign tax laws often fall short of ensuring that U.S. expats…
Read MoreWith the recent heavy focus on Congress and the Trump’s administration’s tax reform proposals, it can be easy to forget that the IRS continues to proactively crackdown on offshore tax evasion.
Read MoreOne of the major economic fallouts of last year’s Brexit referendum was the sudden and significant depreciation of the British pound. Over the past week, the pound fell sharply again following the…
Read MoreOne of the more common issues that our clients face in their expat tax filings is determining the proper tax treatment of the sale of their personal residence abroad. The following are some of the…
Read MoreAs we’ve blogged about previously, self-preparing your tax return can be a risky endeavor, especially for U.S. expats with heightened reporting obligations.
Read MoreA recent U.S. District Court case has again shone a spotlight on the lack of a clear statutory or regulatory definition of “willful” for purposes of applying the more severe penalties for failure to…
Read MoreIn a recently published Chief Counsel Advice, the IRS chief counsel’s office offered advice to taxpayers participating in its tax amnesty programs regarding the issue of whether refunds for past…
Read MoreThe Trump administration has revealed its official tax reform plan. While it’s clear that the plan would make drastic changes to the current U.S. tax system, the brevity of the plan leaves a host of…
Read MoreThe IRS recently finalized regulations, previously in proposed and temporary form, which provide guidance on determining the ownership of a passive foreign investment company (PFIC) and the reporting…
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