A near-record number of U.S. citizens and green card holders expatriated in calendar year 2017—5,133 as reported by the IRS[1]—and this list is widely considered to undercount the true number of expatriates. In fact, since 2010, when Congress passed the Foreign Account Tax Compliance [...]
Many of our clients are self-employed consultants who perform their consulting services both in and outside the United States. Many of these clients have asked us how the new tax reform law might affect them. Specifically, they are inquiring about whether they qualify for [...]
On November 27, 2017, the engagement of Prince Harry and Meghan Markle was announced to the press.[1] Prince Harry asked Markle to marry him in London, and the couple recently set the wedding date for May 19, 2018.[2] Ever since the engagement date was [...]
The IRS appears intent on the continued crackdown of U.S. persons who have failed to properly report their full worldwide income and foreign financial assets to the U.S. government. Consolidation of Elite Specialists in Foreign Asset and Income Reporting On August 2, the IRS [...]
January 30, 2017 Synopsis Last week, a U.S. District Court authorized the IRS to summons a taxpayer with access to information about clients' undisclosed foreign financial assets. Given the IRS’ increasing efforts to discover hidden foreign accounts, The Wolf Group encourages U.S. taxpayers with foreign accounts to take [...]
Taxpayers who have financial assets outside the United States often ask this question when they are considering how (or whether) to come clean and inform the IRS about their previously undisclosed foreign financial accounts. For years, there was little public knowledge of the U.S. [...]
The U.S. income tax system is one of the most complex in the world, with over 70,000 pages of laws and regulations. In addition, the U.S. tax law provides special tax provisions that only apply to international organization (“I/O”) employees and their families. Given [...]
A little known statute authorizing the collection of comprehensive financial information of US persons with foreign investments has been receiving a great deal of attention recently particularly by those unaware of the filing requirements and associated stiff penalties for non-compliance. The information in question [...]
Most G-4 visa holders working full-time for international organizations are treated as nonresidents for U.S. income tax purposes (please click here for a detailed discussion of G-4 tax residency issues). If a nonresident is married to a U.S. citizen or other U.S. income tax resident, [...]
As a result of the increasingly burdensome international tax and regulatory regime in the United States (see “IRS Eyeing International Taxpayers”), many more U.S. citizens and permanent residents are considering renouncing their citizenship or relinquishing their green cards than did so in the past. [...]
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