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Exit Tax Form 8854 Changes and Common Procedural Errors
In Part 1 of our series on the final Exit Tax regulations issued by the IRS on January 14, 2025, we looked at §2801 tax implications for US individuals who receive certain gifts or bequests (either directly or indirectly) from someone who [...]
Risk and Recordkeeping Requirements for Form 708 Filing To Report Receipt of a Covered Gift or Bequest
In Part 1 of our series on the final Exit Tax regulations issued by the IRS on January 14, 2025, we looked at §2801 tax implications for US individuals who receive certain gifts or bequests (either directly or indirectly) from someone who [...]
If You Expatriated from the US, Be Careful in Making Gifts to US Individuals
Individuals who gave up their US citizenship or long-term tax residency (or will do so) and are deemed to be covered expatriates subject to the US Exit Tax (or will be in the near future), should take great care when making gifts [...]
Proposed Regulations Issued in 2024 Affect Your Options for Foreign Pension Reporting
The IRS issued proposed foreign trust regulations on May 7, 2024, which offer certain taxpayers additional relief from burdensome foreign pension reporting requirements. But they don’t come without risk. On the positive side, if you have an interest in a foreign pension, [...]
IRS Increases Scrutiny on Non-Residents Who File Joint Tax Returns with Their US Resident Spouse
US non-residents (for tax purposes) must make a special election in order to file joint tax returns with their US tax resident spouses. Changes to individual income tax forms for 2024 indicate that the IRS may be taking a closer look at [...]
IRS Gives Additional Time To File (and Sometimes To Pay) to Taxpayers Affected by 2024 Disasters
The IRS granted relief to taxpayers affected by the numerous hurricanes, fires, and other disasters in the US and Israel during 2024, offering additional time to file some 2023 and 2024 tax returns (and other reports) and, for some types of tax [...]
IRS Releases the 2025 Inflation Adjustments
Every year, the IRS makes inflation adjustments to various items, such as the standard deduction, estate tax unified credit, tax brackets, etc. On October 22, 2024, the IRS released Rev. Proc. 2024-40 with the 2025 inflation adjustments. Here are some key inflation [...]
IRS Requests Comments on Voluntary Disclosure Practice and the Streamlined Filing Compliance Procedures
The IRS is seeking comments and input from the general public on the main programs taxpayers can use to obtain penalty relief for late reporting of foreign financial assets and foreign income. Background Generally, when individuals or businesses fail to report foreign [...]
IRS Will Not Assess Automatic International Civil Penalties for Late-Filed Forms 3520 and 3520-A
On October 24, 2024, IRS Commissioner Daniel Werfel announced that the IRS will no longer automatically assess international civil penalties for late-filed Forms 3520 and 3520-A.1 Background on Forms 3520/3520-A filing requirements and penalties Internal Revenue Code §6048 requires United States tax [...]
Executive Order: US Professionals Can No Longer Provide Services to Clients inside the Russian Federation
As of June 7, US companies and individuals will be prohibited from providing services to anyone located within the Russian Federation, including US citizens living in Russia. Background On April 6, 2022, President Biden signed Executive Order 14071, prohibiting new investment and [...]
