Citizenship-based reporting: Mr. #FBAR as a role model for President Putin and the Russian government

Via @NPR: Steven Seagal Is Now A Citizen Of Russia, Courtesy Of Putin – Welcome to the Russian version of Mr. #FBAR — Citizenship Lawyer (@ExpatriationLaw) November 22, 2016   It has been widely reported that American actor Steven Seagal has joined American boxer Roy Jones in becoming a citizen of Russia. By becoming […]

False Form 8854 used as part of "willful" #FBAR prosecution

The primary story is of a U.S. professor who pleaded guilty to an FBAR violation and was subjected to a 100 million FBAR penalty. ┬áNotably the “tax loss” was 10 million dollars and the FBAR penalty was 100 million dollars. It appears that Mr. FBAR is becoming an important tool in the arsenal used by […]

Around the world in 192 pages: Experiences of #Americansabroad in an #FBAR and #FATCA world

@ExpatriationLaw is this still available or posted anywhere? — CrossBrit (@CrossBriton) October 29, 2016 Here it is: richardsonkishcommentsamericansabroadapril152015internationaltax-2 This is one of seven parts of the Richardson Kish submissions to the Senate Finance Committee in April of 2015. I thank Patricia Moon for her unbelievable effort in putting this document together! And speaking of Americans […]

Will a business trip to the United States of America trigger a "chance" encounter with Mr. #FBAR?

Prologue: Circa 1948 – George Orwell anticipates the arrival of Mr. FBAR In his classic book "1984", George Orwell anticipated the "reporting requirements" that exist today. — Citizenship Lawyer (@ExpatriationLaw) August 24, 2016 ‘By the way, old boy,’ he said. ‘I hear that little beggar of mine let fly at you with his catapult […]

Scenes from the #FBAR Marriage: what can happen if #Americansabroad share a bank account with a non-US person

Part 1 – The problem of a U.S. person sharing financial accounts with a non-U.S. person – Probably better to NOT do it! Q. Why should #Americansabroad should NOT share bank account with non-U.S. person? A. Can trigger #FATCA Form 8938 — Citizenship Lawyer (@ExpatriationLaw) June 9, 2015 The above tweet references the following […]

If (U.S. Person) then (Mr. #FBAR Ms. #PFIC and Uncle #FATCA) = Few investment and financial planning opportunities).

U.S. #Expat Tax Conference – Toronto – November 13, 14/14 – Opportunity to meet Mr. #FBAR Ms. #PFIC and Uncle #FATCA — Citizenship Lawyer (@ExpatriationLaw) September 22, 2014 Deborah Hicks International – U.S. Expat Tax Conference – November 13, 14/2014 Toronto. US expat tax and finance conference Toronto 2014 leaflet This conference is similar […]

#Americansabroad: Thoughts on the May 2/14 Toronto Conference on CBT vs. RBT – #FATCA #FBAR

#Americansabroad: @JackieBugnion of @ACAVoice comments on May 2/14 Toronto Conference/Debate on CBT vs. RBT #fatca — John Richardson – lawyer for "U.S. persons" abroad (@ExpatriationLaw) July 10, 2014 #Americansabroad: Mary-Louise Serrato of ACA Global discusses May 2 Toronto RBT v. CBT debate — Citizenship Lawyer (@ExpatriationLaw) July 10, 2014 ACA Global Foundation […]

#FBAR Lawyer – Needed by Americans in Switzerland

U.S. born citizens and residents of Switzerland need an #FBAR lawyer and that's a #FATCA — Citizenship Lawyer (@ExpatriationLaw) June 11, 2014 Introduction – It’s about “disclosure” and penalties for “non-disclosure” On June 9, 2014 U.S. lawyer Robert Wood wrote a short but interesting article titled: “Offshore Bank Letters, FATCA & IRS Penalties – […]

CARES Act Relief: How US citizen taxation leads to sending relief money to individuals outside the United States and denies relief money to individuals inside the United States

Introduction This post is based on my Quora answer to the question: “Do you agree with the policy of not issuing checks to US citizens who jointly file taxes with someone who has an ITIN?” Part I – Objective Analysis This post focuses on the class of individuals entitled to relief. It does not discuss […]

Treasury exempts applicable “tax-favored foreign trusts” from the Form 3520 (and therefore Form 3520A) requirement

Introduction – A small step for forms, one giant leap for “formkind” It’s true. Many Americans abroad may no longer be required to file Form 3520 and Form 3520A to report their lives abroad! Early indications appear that many Americans will (assuming their retirement vehicle does qualify as a trust) not be required to report […]