How might marrying a non-US citizen affect your taxes? What are some of the hidden issues that the IRS, California, and other state tax agencies may raise in an audit? Key Takeaways: The Ways in Which Marrying a Non-US Citizen Affect Your Taxes: The United States taxes the worldwide income...
FBAR Requirements as a U.S. Person for an Offshore Account
What are your FBAR requirements as a U.S. person or taxpayer for an offshore account, group of accounts, property, or investment? The penalties associated with non-compliance with the reporting of offshore accounts, assets and income are quite severe. Primary Takeaways Regarding FBAR Requirements as a U.S. Person or Taxpayer With...
U.S. Taxpayers with Offshore Investments Should Be Wary of PFICs
U.S. taxpayers with offshore investments should be wary of PFICs (Passive Foreign Investment Company). Many foreign nationals live and work in the United States. For those who invest in offshore companies that generate income in a passive nature (i.e. rents, royalties, interest, income from commodities or derivative trading) are permanent...
US Taxpayers and Expatriates May Need to File Offshore Disclosures and FBARs
How many U.S. taxpayers and expatriates may need to file offshore disclosures and FBARs with the IRS? Should those who have not yet filed a disclosure application utilize the VDP (Voluntary Disclosure Program) or a streamlined application through the Streamlined Filing Compliance Procedures or SFCP? Many U.S. taxpayers have taken...
Tax Developments for U.S. Expatriates
There have been many recent tax developments for U.S. expatriates. It is essential for U.S. citizens residing outside the United States and those considering an expat life to understand their responsibilities as U.S. taxpayers. Allen Barron is a strong resource and service provider for U.S. expats, and those with international...
Serious Challenges for Expats and Those Considering Moving Abroad
The world is an ever-changing, ever-evolving crucible of financial and other serious challenges for expats and those considering moving abroad, as well as foreign nationals living and working in the United States. Oversight, tax exposure, and reporting requirements become more challenging each year. Financially speaking, the world in 2025 has...
A Foreign Trust Creates Complex IRS Reporting Requirements
The IRS has clearly identified legitimate reasons why "U.S. Persons" would establish or maintain ownership in a foreign trust. However, a foreign trust creates complex IRS reporting requirements for US taxpayers who own a foreign trust under the grantor trust rules, or are beneficiaries with an investment in a foreign...
Foreign Corporate Ownership and Investments
Are you involved in offshore or foreign corporate ownership and investments? Do you have real property, assets, or foreign bank or investment accounts? U.S. taxpayers with offshore business interests, holdings, investments, and bank accounts need an experienced U.S. international tax attorney as well as integrative business, legal, and accounting services. ...
What is Willful Blindness According to the IRS?
What is willful blindness according to the IRS? How is this important in tax cases involving unreported or under-reported income, disclosure of offshore assets and income, FinCEN Form 114 (more commonly referred to as an "FBAR"), and even digital currencies and Non-Fungible Tokens (NFTs)? In an internal IRS memorandum from...