The Ins and Outs of Gifting PFICS
To get this blog started, let’s take the following situation (which is not so uncommon): A U.S. citizen living abroad holds a portfolio of foreign mutual fund investments and decides that he’d like…
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Tax Court Rules Against IRS on Form 5471 Penalties
On April 3, 2023, the U.S. Tax Court, in Farhy v. Commissioner, 160 T.C, No. 6 (April 3, 2023), made a surprising but welcome decision on international form penalties. The Court held that the IRS…
Read MoreSelf-Employment and Social Security Taxes for Expats
It’s a well-known expat tax basic that U.S. citizens living abroad have a number of unique tax challenges and opportunities.
Read MoreUS Supreme Court Decision on FBAR Penalties
In a welcome decision for the U.S. expat community, the U.S. Supreme Court has ruled against the IRS on the issue of the scope of FBAR penalties, significantly reducing the proposed penalties on the…
Read More2023 Tax Deadlines for Expats
Now that the tax season is well under way, we thought it would be worthwhile to review the key tax deadlines for U.S. expats during 2023.
Read MoreIRS Form 8832 and Foreign Trusts
For U.S. business owners living abroad, one of the key U.S. basic concepts to understand is that your foreign entity may be classified differently under the U.S tax law than its legal classification…
Read MoreLimitations on the Foreign Exclusion for Self-Employed Expats
For U.S. persons living abroad, the foreign earned income exclusion (“FEIE”) under Section 911 of the Internal Revenue Code provides a significant measure of tax relief against the U.S. government’s…
Read MoreThe QEF Election for PFICs
When investing in a business overseas, expats should be wary of the passive foreign investment company (“PFIC”) rules, which trigger heightened reporting requirements and can have onerous tax…
Read MoreInstallment Sales - US Tax Considerations
In this blog, we cover the U.S. tax consequences of installment sales, both for immigrating aliens and for expatriating U.S. persons. We base our analysis on court cases and IRS guidance. We note…
Read MoreInflation Adjustments for 2023 Tax Items
While many tax figures, such as exclusions or penalties, remain the same from year to year, there are certain numbers that are adjusted typically on annual basis, taking into account inflation and…
Read MoreNew Filing Penalty Relief
In an unexpected but welcome move, the IRS issued Notice 2022-36 on August 24, which provides fling penalty relief to taxpayers who filed certain 2019 or 2020 returns late.
Read MoreTaxation of Pension Contributions and Earnings
For Americans living abroad, one of the trickier areas of U.S. tax law is the non-U.S. pension. Despite being a common feature of most people’s lives, the U.S. Treasury and IRS provide limited…
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