The United States has entered into income tax treaties with several countries that provide for the exchange of information.[i] But only “five treaties provide for assistance in collecting tax judgments against U.S. citizens living abroad.”[ii] Those are with the following countries: Canada, France, Holland, Denmark and Sweden.[iii]

Let me explain to you what I mean by “collection of tax judgments.” Specifically, I’m referring to the ability of the United States to collect tax claims against its own citizens who happen to be living in one of these five countries.[iv] Because these treaties are bilateral, the reverse is also true: partner countries may collect tax claims against their own citizens who happen to be living in the United States.[v] Read More

I received a panicked call from a client recently, being detained at a major metropolitan airport. The client, a nonresident United States taxpayer, owed money to the IRS. Upon investigation, I learned who was responsible for detaining him: none other than the IRS. Under what authority? A two-year-old program designed to target nonresident delinquent taxpayers who travel to and from the United States.

New York tax practitioners can soon expect to receive similar calls. Dubbed the “contact program,” it has a clear objective: to improve tax administration and compliance among nonresident U.S. taxpayers. In what ways?

(1) By collecting delinquent taxes; Read More