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Lessons Learned Preparing & Defending IRS Form 8938 – FATCA

The Perturbing New Treatment of Patents Under the Tax Cut & Jobs Act (TCJA)

Foreign Financial Asset Reporting (FATCA) - Form 8938 was enacted March 18, 2010 and requires filing of Form 8938. The FATCA requirement does not replace or otherwise affect a taxpayer’s obligation to file an FinCEN Form 114. Basically if you are a US

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Posted in FATCA, FBAR, Foreign Income, Foreign Investment, International Tax, Tax Treaties

Foreign Earned Income Exclusion (FEIE): Drill Down into IRS Form 2555

The Perturbing New Treatment of Patents Under the Tax Cut & Jobs Act (TCJA)

We get all sorts of fascinating questions from established US Taxpayers as well as those experiencing internationalism for the first time. It seems regardless of the degree of sophistication in US income tax filing obligations most people are out to

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Posted in FATCA, FBAR, Foreign Income, Foreign Investment, International Tax

What is an ITIN? T.D. 8671, 1996-1 C.B.314

In 1996, the U.S. Treasury Department issued T.D. 8671, 1996-1 C.B.314 introducing the ITIN - Individual Taxpayer Identification Number - requiring people foreign to the USA to use a unique identification number on their United States federal income tax returns. These

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Posted in FBAR, International Tax, ITIN, Taxpayer Identification Number

Tax Implications of US Expatriation; Internal Revenue Code 877A

Year End Tax Planning Starts with a Charitable Donation Assessment How Do You PLAN to Give Back Next Year?

I was brought in on another interesting file this week involving a US Citizen seeking expatriation that I was strongly advised to run away from by my mentors and friends simply because it is easy to paint a picture of these

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Posted in Expatriation, FBAR, International Tax

Reporting Investments In Certain Foreign Corporations for U.S. Tax Purposes

As we increasingly become more connected on this planet US Taxpayers are compelled more than ever before to hold investments in multiple countries. As a direct result timely filing IRS Form 5471 is becoming profoundly significant. I've been involved with enough international

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Posted in CFC, Corporation, FBAR, Foreign Income, International Tax, IRS Enforcement, IRS Examination, Tax Guidance & Preparation
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