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Monday, September 14, 2015

IRS Proposes Rules on Gifts and Inheritances from Expats

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The proposed rules stem from the Heroes Earnings Assistance and Relief Tax Act of 2008, or “HEART Act,” which applied to certain individu...
Sunday, August 16, 2015

Link

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Interesting FATCA/CBT/FBAR discussions here: http://reddit.simonvreux.be/p/33y057/new
Thursday, August 13, 2015

lol....US Department of Justice blames Americans abroad for their own FATCA injuries

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The US Department of Justice has issued a 57-page response to the filing of a Motion for a Preliminary Injunction by the James Bopp FATCA ...
Wednesday, August 12, 2015

Green cards and treaty elections

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If you have a green card and live abroad (in a country that has an income tax treaty with the United States) you can choose to be taxed a...

some guidance with regards to OVDP or SFCP

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The choice of program should be guided by the facts and circumstances. It is a function of the source of your offshore funds, the nature o...
Tuesday, August 4, 2015

Case : Form 8854 was not filed when green card abandoned

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Case : A long-term resident returned to CH in 2013 and filed Form I-407 to abandon her green card. She was not a covered expatriate bec...
Friday, July 31, 2015

Foreign Bank Account Report (FBAR) Filing Date Extended by HR 3236‏

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Today, July 31, 2015, President Barack Obama signed into a law HR 3236 a highway funding bill. Buried in the Bill is a provision which cha...

Moore v US / Western District of Washington Punishes IRS for Failing to Justify or Explain Itself in FBAR Case‏

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In M oore v US   judges hold up IRS misconduct to the bright and sanitizing light of judicial review.    One benefit that hopefully come...
Wednesday, July 29, 2015

Determining “Reasonable Cause” for Non-Willful FBAR Violations

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For violations involving the non-willful failure to report the existence of a reportable interest in a foreign financial account, the ma...
Tuesday, July 28, 2015

UBS Too Dirty To Sue Billionaire Offshore Tax Cheat, Judge Rules

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Billionaire offshore tax cheat Igor Olenicoff has won a big one in his long running court battle with his former Swiss bank, UBS...
Monday, July 27, 2015

green card holder case study

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My original question / case ——————————- * 5+ year green card holder, EU citizen * Looking to potentially get US citizenship * No FBARs ...

IRS Advises re Delinquent International Information Return Submission Procedures

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Taxpayers who do not need to use the OVDP or the Streamlined Filing Compliance Procedures to file delinquent or amended tax returns to re...
Saturday, July 25, 2015

Residence-Based Taxation: A Necessary and Urgent Tax Reform

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Contents RBT Executive Summary Introduction Understanding current law Residence-based taxation Positive consequences of RBT ...
Tuesday, July 21, 2015

Form 1040NR with Form 8833 attached or Green card + treaty election = exit tax danger

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This matters to you if you are a green card holder: thinking about expatriating, or you want to keep the green card, live abroad, and...
Sunday, July 19, 2015

Ex-US Rep. Michael Grimm Gets 8 Months For Tax Fraud

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Former Staten Island Rep. Michael Grimm was sentenced to eight months Friday for under-reporting taxes from a restaurant business after a ...

TAS Objectives for 2016 report

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http://www.taxpayeradvocate.ir...
Tuesday, June 30, 2015

Personal residence exclusion under exit tax rules

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American citizens who give up their American citizenship (expatriates) are classified into covered expatriates and non-covered expatriate...
Wednesday, June 24, 2015

FBAR and Tax Crime Statutes of Limitations – Suspended When Overseas?

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What is a Statute of Limitations (SOL), Generally? The tax laws contain what is known as a statute of limitations. The statute prescribes ...
Tuesday, June 23, 2015

Relinquish your U.S. citizenship or their green card, but have not filed FBARs.

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It is possible to expatriate, not file FBARs, and certify to the IRS that you have complied with your tax obligations. It is not necessar...
Tuesday, June 16, 2015

Use Form W-8BEN to eliminate US tax

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When a US person (like, say, a 401(k) plan administrator) pays taxable income to someone outside the United States, 30% must be subtracte...
Tuesday, June 9, 2015

Covered gift and bequest from covered expatriate

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In the article, 'The New Rules of Offshore Accounts' , that last paragraph states that if a person receives a gift/bequest from...
Friday, June 5, 2015

The chances of having your tax return audited by the IRS.

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The Chances of Being Audited 2014 audit statistics show changes Every year the IRS publishes the statistics of the number of tax return...
Saturday, May 30, 2015

Joint accounts : the date of the FBAR filing violation is 6/30 of the year following the calendar year for which the account is being reported

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--------- For each co-owner against whom a penalty is determined, the penalty will be based on the co-owner's percentage ownership of t...

New IRS FBAR Penalty Guidance

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Heather Maloy, Commissioner, LB&I, has issued a memo dated 5/13/15 titled Interim Guidance for Report of Foreign Bank and Financial Acco...

Most Recent IRS International Hacking Reveals Vulnerability

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According to national reports, hackers allegedly stole the personal data of approximately 100,000 taxpayers from the IRS’s computer sys...
Wednesday, May 27, 2015

Swiss naming of suspected tax cheats causes waves - Bundesblatt Nr. 19

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When Switzerland makes a decision to turn over bank information of a foreign depositor upon request of a treaty party, the depositor is ...
Tuesday, May 26, 2015

Florida CPA Charged with Filing Fraudulent Tax Returns

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A Florida CPA has been arrested and charged with using her tax preparation business to facilitate an income tax refund fraud scheme.

Pre-Expatriation Gifts and A step-by-step "how to" -- answering the key question on a gift tax return to report such a gift.

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One of the easiest ways to bring your net worth down below $2,000,000 -- and be a noncovered expatriate -- is to give stuff away. U.S. citi...
Monday, May 25, 2015

The IRS Scandal, Day 746

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House Republicans formally asked the IRS to review whether the Clinton Foundation is complying with the rules governing its tax-exempt st...
Wednesday, May 20, 2015

Survey Shows Rise in U.S. Expats ‘Seriously’ Mulling Renouncing Their Citizenship

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76% of respondents do not feel they should be required to file US taxes 86% said they do not feel they are well-represented in the US gove...
Tuesday, May 19, 2015

Conditional green card = green card

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A "permanent resident" visa is commonly called a "green card" because that is what the piece of plastic more or les...
Tuesday, May 12, 2015

FinCEN Provides Additional E-Filing Method for FBAR Individual Filers

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The Financial Crimes Enforcement Network (FinCEN) has announced that the BSA E-Filing System now provides an alternative E-Filing method fo...

What happens to the 10% early distribution penalty on a retirement account if a covered expatriate had paid the exit tax on the account ?

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A traditional IRA that had a pretend distribution under section 877A(e). A 401(k) for which the covered expatriate forgot to give Form W-...
Tuesday, May 5, 2015

The mechanics of Form 8854

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If you are late filing Form 8854 you will be a covered expatriate. Someone who expatriated in 2013 would have a filing deadline for Form 88...
Monday, May 4, 2015

IRS Officer Busted for Identity Theft and Fraud

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An Internal Revenue Service revenue officer has been indicted for committing mail and wire fraud, filing false tax returns...