Here are the answers in a hurry:
Covered expatriates risk being taxed twice: once by the United States on assets they own when when they expatriate, and a second time by their home country when they sell assets or take pension distributions.
The double taxation problem has been largely solved for expatriates who live in Canada, but not (as far as I know) for other residents of countries.What’s a Double Taxation Problem?
Let’s talk first about what a double-taxation problem is. It occurs because two countries want to tax you, and neither country cares that the other country taxed you.
If you are a taxpayer in two different countries, both countries will impose their domestic tax laws on you, and insist on the right to force you to pay tax on your income.... continue reading
Today’s topic is based on some war stories we have seen. Here is the general situation we have had to deal with:
I am a US citizen living abroad and married to a foreign national. She and I both owned some PFICs. We transferred them to a family trust whose trustee is a private company we own 50-50. Our children and we are beneficiaries of the family trust. Do I have to report the PFICs held in the family trust as my own?
Today’s post will discuss some of the uncertainties and possible results for PFIC attribution through a trust.
This Tax Court Memorandum opinion is currently only available on (extremely overpriced and God-awful UI) Lexis via Tax Notes Today. (How do you take something terrible and make it worse? Lexis Advance is your answer).
I do not see the opinion anywhere on the Tax Court’s website. In order to make it available to everyone, I am posting it here.
The opinion demonstrates the procedural aspects for filing a late Form 2555.
DAMON AARON REDFIELD,
COMMISSIONER OF INTERNAL REVENUE,
RespondentUNITED STATES TAX COURTFiled April 26, 2017
Damon Aaron Redfield, pro se.
Jeffrey E. Gold and Stephen C.... continue reading
We finally have sane filing deadlines for income tax returns and FBARs (FinCen Form 114). But there is still a trap for the unwary.
Humans file income tax returns by April 15 .1
Humans can get extensions of time to file their income tax returns: