President Trump unveiled his latest framework for tax reform, which stems from a collaborative effort by the so-called “Big Six,” which includes members of the Trump administration and Senate and House leaders.

The following is a quick summary of some of the main provisions of the plan, which have potential consequences for U.S. expat individuals: Read More

The linchpin legislation of the U.S. government in its effort to combat tax evasion abroad over recent years has been the Foreign Account Tax Compliance Act (FATCA). Last week, the latest legal challenge to FATCA was thwarted when the United States Court of Appeals for the Sixth Circuit affirmed a lower court’s decision to dismiss the case against FATCA.

Quick FATCA Background Read More

For many U.S. expats who are delinquent in their expat tax filings, the Streamlined Procedures offer a great solution for catching up with limited or no penalties.  Due to the Streamlined program’s qualification requirements, however, American citizens living in Canada, or other countries, who regularly visit the U.S. may find it particularly difficult to participate in the program. Read More

National Taxpayer Advocate Nina Olson discussed the potential pitfalls of treating information on the IRS’s website, such as its FAQs pages, as authoritative. The Taxpayer Advocate is an independent office within the IRS tasked with helping people resolve tax issues with the IRS and recommending changes that will prevent future problems.

Read More

Previously, we discussed a newly-enacted Code Section 7345 of the Internal Revenue Code, which authorizes the denial, revocation, or limiting of a delinquent taxpayer’s U.S. passport. We noted then that the statutory language contained in the new law offers few details about how exactly the penalty will be administered and to what extent exceptions would apply.

After more than a year-long delay, the IRS finally provided a number of important additional details relating to the passport revocation rule on its website. Read More

Ephraim Moss

In 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 friendlier IRS Streamlined program without utilizing the required transition rules.

The Maze case demonstrates the importance of choosing the IRS tax amnesty program that is right for you from the outset. Read More

According 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 the increase in renunciations include the global strengthening and influence of the Foreign Account Tax Compliance Act (“FATCA”) and President Trump’s election victory (the “Trump bump”). Read More

Despite the overall success of the IRS tax amnesty programs in recent years, many expats remain hesitant to enter the programs due to a number of misunderstandings surrounding their requirements and their outcomes. In this blog, we separate fact from fiction so that you can decide intelligently whether tax amnesty is right for you. Read More

The 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 are on equal tax footing with their non-expat counterparts. In such case, a relevant tax treaty may be available to pick up the slack. Read More

Ephraim Moss

With 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 More

Ephraim Moss

One 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 unexpected results of the most recent U.K. election.

What does this mean from a tax perspective for U.S. expats living in the U.K.?

Read More

Ephraim Moss

One 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 key U.S. tax considerations when selling a foreign residence. Read More