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Author Archives: Patrick Hoza

Look Before You Leap…or GIFT – US Gift Tax Exemption

While the US estate and gift tax exemption currently stands at a hefty $11.7 million (2021), it does not mean that you will benefit from it on a gift you make today. Due to President Biden’s historic win, Americans are facing down the barrel at some potentially drastic changes to the tax law. Under proposed […]

Expatriation the Easy Way or How I Learned to Give Up My US Citizenship and Breathe Freely Again

Lefty Gomez, an all-star pitcher for the New York Yankees in the 1930s, is credited with saying “I’d rather be lucky than good.” He is also credited with earning the nicknames “Goofy Gomez,” and “El Goofo.” Still, I often think Lefty had it right and today could very well be your lucky day. If you […]

Retrocessions: Claims from Swiss Banks – Don’t Leave Money on the Table

Retrocessions were a hidden fee certain Swiss funds paid banks to funnel the banks’ clients into specific investment vehicles. This fee was hidden from the clients. The Swiss courts have issued various rulings between 2006 and 2017 relating to the refundability of the payments to the clients. The 2017 ruling set the statutory limitation period […]

Qualified Opportunity Zone (QOZ) / Qualified Opportunity Fund (QOF)…

…While these terms do not roll off the tongue, they present the in-the-know investor with a wonderful opportunity. Created as part of the Tax Cuts and Jobs Act of 2017, a QOZ is an economically distressed community in the United States where new investments get preferential tax treatment. The QOFs, in turn, are investment structures […]

FBAR Non-willful Penalties Are Real

While there has been no official change to the current FBAR penalty rules we laid out in 2015, it should be noted there was a recent court case which has reached an unfavorable result for taxpayers with regard to potential FBAR non-willful penalties. In an April 2019 California District Court case (U.S. vs Boyd), the […]

2019 US Year-End Tax Planning

The US tax year ends on 31 December 2019. As always, the final months of the year provide an opportunity to focus on 2019 year-end tax planning opportunities available to optimize US tax for the 2019 tax year. Effective year-end tax planning starts with understanding both current circumstances and subsequent year issues that may affect a […]

IRS Tax Form Update – Virtual Currency

Please note, the IRS released an early draft Form 1040 for the 2019 tax year which contains a new item – 2019 Form 1040, Schedule 1, Additional Income and Adjustments to Income. The checkbox at the top of Schedule 1 asks taxpayers about their interests in virtual currency. Specifically, it states, “At any time during 2019, […]

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