Tax Blog

Contents1 How to Navigate an FBAR Examination2 First, can you Prevent an FBAR Audit?3 FBAR Statute of Limitations and Civil […]
Contents1 Expatriation Tax Planning for Long-Term Residents and U.S. Citizens 2 First, What is IRC Section 877A?3 Net Worth vs Exit […]
Contents1 2025 Expat FBAR Guide: New Filing and Reporting Examples2 First, a Quick FBAR Intro3 Bank Accounts4 Pooled Funds (Account […]
Contents1 Common Form 8938 Examples for Expats, Residents, and Citizens2 Who Has to File Form 8938?3 What are the Form […]
Contents1 How New U.S. Persons File Taxes 2 Worldwide Income Taxation3 Foreign Bank Account Reporting (FBAR)4 Form 8938 (FATCA)5 Form 3520 […]
Contents1 The IRS To Eliminate ‘Automatic’ Late Form 3520 Penalties2 First, Why Are Form 3520 Penalties a Problem?3 What Will […]
Contents1 If I have a U.S. Visa, Do I Have to File Taxes? 2 First, What is the Substantial Presence Test?3 […]
Contents1 When Do I Calculate the Expatriation Tax and How2 First, Net Worth vs Exit Tax3 Mark-to-Market Gains4 Eligible Deferred […]
Contents1 How U.S. Expats Can Avoid Criminal Tax Violations2 FDAP vs ECI3 Treaty or Non-Treaty Country4 W-8 BEN to Reduce […]
Contents1 Do I Qualify for IRS New Voluntary Disclosure Practice (VDP)?2 Timing a VDP Submission is Crucial3 Taxpayers Must Certify […]
Contents1 Reporting Foreign Pension Income to the IRS2 First, Employment Retirement vs Personal Retirement3 Treaty vs Non-Treaty4 Form 1040 Tax […]
Contents1 5 Essential Compliance Factors for a Successful Offshore Disclosure 2 Willful vs Non-Willful3 Which Offshore Disclosure Program is Right […]
Contents1 IRS Form 3520 CP15 Notice Penalty Response2 Why Did Taxpayer Receive a Form 3520 Penalty?3 30-Days to Show Reasonable […]
Contents1 Understanding Australian Superannuation2 Is Your Australian Super Treated as U.S. Social Security?3 How are Employer Contributions Taxed?4 Are Voluntary […]
Contents1 Common Tax Mistakes About Ending Citizenship or Residency 2 You Must Be Compliant Before You Terminate Status3 Five-Year Tax […]
Contents1 Why Act 60 is Not an Alternative to Renouncing Citizenship2 Is Act 60 An Alternative to Expatriation?3 First, Taxpayers […]
Contents1 Foreign Pension Reporting on Taxes and FBAR2 U.S. Pension vs Foreign Pension3 Foreign Retirement Income4 FBAR (FinCEN Form 114)5 […]
Contents1 Can I Speak with an Accountant About a Late-Filed FBAR?2 Late FBAR Attorney-Client Privilege3 What is the Accountant-Client Privilege […]
Contents1 Are Dual-Citizens Required to Report Foreign Accounts (FBAR)2 Example of a Dual Citizen with FBAR Requirement3 Randy is a […]
Contents1 How Long Should I Wait to Disclose My Offshore Accounts?2 Regain Peace of Mind3 Reduced Offshore Penalties4 Offshore Disclosure […]
Contents1 Form 3520 Penalty Explained2 First, a Gift vs Loan3 Individual Large Foreign Gift Example4 Entity Large Foreign Gift Example5 […]
Contents1 Is an IRS Intent to Levy (LT11) Preventable2 What is an LT11 Notice?3 What is an IRS Levy?4 When […]
Contents1 Are Estates On The Hook for a Decedent’s FBAR Violation?2 How Does Death Impact FBAR Penalties?3 Were the FBAR […]
Contents1 What is IRS Form 86212 What is a PFIC?3 PFIC/CFC Crossovers, GILTI, Subpart F and Excess Distributions4 Which Forms […]
Contents1 Navigating U.S. Tax and Immigration Issues2 Worldwide Income3 Opening Foreign Accounts4 FBAR Reporting and FATCA Disclosures by Banks5 Owning […]
Contents1 An IRS Form 8833 Beginner’s Guide 2 What is Form 8833?3 Expatriation Tax Trap4 Not all Treaty Elections Require a […]
Contents1 Are FBAR Fines Unconstitutional Under the Eighth Amendment?2 The Ruling Summarized3 FBAR Willfulness Penalties4 Are FBAR Penalties Punitive?5 Key […]
Contents1 Overview of Foreign Pension for U.S. Expats2 First, Employment Retirement vs Personal Retirement3 Treaty vs Non-Treaty4 Form 1040 Tax […]
Contents1 Another Court Finds that FBAR Willfulness Includes Recklessness2 Procedural Background3 Safeco and Willfulness4 Safeco Applies to FBAR Willful Penalties5 […]
Contents1 Does an IRS Notice CP508C Mean You Lose Your Passport?2 26 U.S. Code § 7345 – Revocation or denial […]
Contents1 Common Pitfalls for Expats with Undisclosed Overseas Accounts2 What IRS Tax Forms are Required for Foreign Accounts?3 FATCA Letters […]
Contents1 A Comparison of Form 8938 and FBAR2 5 Things to Know About FBAR3 FBAR has a Single Threshold 4 […]
Contents1 Hastily Prepared Offshore Disclosures are Ill-Fated & Risky2 You Just Learned You are Non-Compliant and Want it Done ASAP3 […]
Contents1 Tax Warnings For Green Card Holders/Permanent Residents2 Permanent Residents Can be Subject to Exit Tax3 The Pre-Expatriation Gifting Rules […]
Contents1 Explaining FBAR Basics in Under 10 Minutes2 Who is a US Person for FBAR Purposes?3 What Is a Financial […]
Contents1 Common Tax Problems & Solutions for Citizens and Green Card Holders2 Make a Treaty Election3 Plan Before Acquiring Foreign […]
Contents1 Taxpayer Prevails on FBAR Filing Treaty Election2 The IRS Says a Treaty Election Does Not Eliminate FBAR3 FBAR Practice […]
Contents1 Delinquent FBAR Submission Procedures2 Submission Procedures for Delinquent FBAR 3 Follow these steps to resolve delinquent FBARS4  Review the Instructions5 […]
Contents1 How to Certify and Non-Willfulness Avoid Streamlined Mistakes2 Common Streamlined Filing Compliance Mistakes to Avoid3 Properly Analyzing the Willfulness/Non-Willfulness […]
Contents1 You Can Make an Error on Schedule B and Be Non-Willful2 IRS Understands that Schedule B FBAR Mistakes Happen3 […]
Contents1 What is IRS Form 8938, Who Must File & Report Foreign Assets 2 When is Form 8938 Required?3 Taxpayers […]
Contents1 What is an Offshore Tax Law Specialist?2 First, Becoming a California (Board-Certified) Tax Specialist3 Is a CPA ‘Board’ the Same […]
Contents1 IRS Form 8938 Reporting Thresholds for Expats2 Single Taxpayer Living in the U.S.3 Single Taxpayer Living Abroad4 Married Taxpayer […]
Contents1 Is an IRS Streamlined Disclosure the Best Option?2 Taxpayer is Willful3 Taxpayer Did Not File Original Tax Returns (Domestic […]
Contents1 Does Offshore Disclosure Require Expats to go to IRS In-Person?2 VDP (Voluntary Disclosure Program)3 Streamlined and Delinquency Procedures4 Examinations, […]
Contents1 The IRS Targets Form 3520 & 3520-A Compliance 2 Common Form 3520 and 3520-A Reporting Examples3 Dana Received a Large […]
Contents1 What are the Penalties for Not Filing FBAR2 Totality of the Circumstance Test3 Intent Is Not Required for FBAR […]
Contents1 Form 3520-A2 What Is Considered to Be A Foreign Trust?3 U.S. Trust with Foreign Assets4 When is a Foreign […]