Expat Taxes
THAI RESIDENTS MUST NOW PAY THAI INCOME TAX ON FOREIGN SOURCE INCOME
THAI RESIDENTS MUST NOW PAY THAI INCOME TAX ON FOREIGN SOURCE INCOME
The Thai Revenue Department recently issued Order No. 16/2023 (the “Order”), which marks a significant…
FORM 5471 FILING REQUIREMENTS FOR U.S. TAXPAYER MARRIED TO NON-RESIDENT SPOUSE
FORM 5471 FILING REQUIREMENTS FOR U.S. TAXPAYER MARRIED TO NON-RESIDENT SPOUSE
The requirements for filing Form 5471 are quite complex and confusing. The obligation to file…
FATCA REPORTING CHANGES AND INFLATION REDUCTION ACT SPELL TROUBLE FOR TAXPAYERS WHO HAVE FAILED TO FILE FORM 8938 AND FBARS
FATCA REPORTING CHANGES AND INFLATION REDUCTION ACT SPELL TROUBLE FOR TAXPAYERS WHO HAVE FAILED TO FILE FORM 8938 AND FBARS
A recent report (the “Report”) from The Treasury Inspector General for Tax Administration (“TIGTA”) addressing…
FIFTH CIRCUIT RULES NON-WILLFUL FBAR PENALTY IS PER ACCOUNT AND NOT PER FORM
FIFTH CIRCUIT RULES NON-WILLFUL FBAR PENALTY IS PER ACCOUNT AND NOT PER FORM
The Fifth Circuit recently held in United States v. Bittner, ___ F. 4th ___ (5th…
COURT ORDERS REPATRIATION OF FOREIGN ASSETS TO AID IN FBAR PENALTY COLLECTIONS
COURT ORDERS REPATRIATION OF FOREIGN ASSETS TO AID IN FBAR PENALTY COLLECTIONS
The issue of whether the Government can repatriate a taxpayer’s foreign assets for purposes of…
INCOME TAX SYSTEMS
Understanding Global Income Tax Systems Understanding how and when the United States imposes federal income…
Taxing Foreign Corporations in the Digital Age
Effectively Connected Income and it’s Tax Consequences Foreign entities that deliver digital goods and services…
Tax Relief for Expats who Renounce U.S. Citizenship
Relief Procedures for former U.S. Citizens The new procedures attempt to address problems faced by…
Residency Based Taxation Legislation Provides False Hope for U.S. Expats
Citizen Based Taxation The origins of citizen based taxation can be traced back to the…
Offshore Disclosure of Foreign Financial Accounts: Deciding What Road to Take
Disclosing Offshore Bank Accounts Taxpayers who are considering coming out of the shadows to disclose…
Fraudulent Tax Resolution Companies
Promises Too Good To Be True In 1931, the famous jurist, Benjamin Nathan Cardozo, in…
Willful FBAR penalty Case Study.
Wilfull FBAR Penalty. The following is intended as an update to my January 26, 2019…