Category: International Tax Blog

What US Expats Should Do with an Australian Superannuation

As a general rule, non-US retirement plans are tricky for US citizens. And you won’t find a trickier example than an Australian superannuation. If you participate in one already, in this article I’ll give you a few friendly suggestions regarding this unfriendly subject. But first, the two big reasons that superannuations are so tricky in… Read more »

Don’t Ignore Your Bank’s “Know Your Customer” FATCA Letter

Do you have US citizenship and a non-US bank account? By now you might have received a FATCA letter from your foreign bank asking about your US tax filing status. Why does your British (or German, or Australian, or wherever) bank care about whether or not you are following US tax rules? The short answer… Read more »

US Citizen with Foreign Life Insurance? Better Call Tax Ghostbusters

As a US tax lawyer, I see ghosts. Poltergeists, actually – the ghosts who cause real damage. The poltergeists are certain types of foreign financial assets which are perfectly normal outside the US. But they wander the separate dimension of US tax regulations and haunt the US citizens who brought them to life. Some of… Read more »

Six Guidelines to Writing an SDOP / SFOP Statement of Facts that Will Be Accepted by the IRS

Six Guidelines to Writing an SDOP / SFOP Statement of Facts that Will Be Accepted by the IRS

  Don’t Be Turned Down for Streamlined Procedures When Trying to Resolve FBAR Reporting Problems If you are thinking about enrolling in the Streamlined Domestic Offshore Procedures (SDOP) or Streamlined Foreign Offshore Procedures (SFOP) in order to resolve delinquent or unresolved FBAR reporting, you will need to be ready to write your “complete story.” That’s… Read more »

How the OVDP Works With Passive Foreign Investment Companies (PFIC)

PFIC Tax Rules – Disclosure Options when you Have Foreign Mutual Funds If you’re a U.S. citizen who has lived or done business outside the U.S. it may have seemed like a good idea to invest in a mutual fund over there, but you need to know the tax rules about passive foreign investment companies… Read more »

Foreign Real Estate and Offshore Disclosure Landmines

Most law-related information on the web comes with a disclaimer towards the end.  When discussing foreign real estate and offshore disclosure, though, I would put the disclaimer at the very beginning: It is strongly suggested that you talk to an attorney with experience in this area. Why at the beginning? Because I want to emphasize… Read more »