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Author Archives: Patrick Hoza

About Patrick Hoza

Patrick has 20 years’ experience with US individual expatriate taxation, including large, multinational programs (Novartis, BP, Hewlett Packard), High Net Worth Individuals, streamline/voluntary disclosure filings, and tax consulting. He has extensive knowledge in serving US expatriates in various issues. He started his career 1990 in California with Westpro as a Senior Tax Consultant and has many years’ experience working with Big Four firms. During his time with Ernst & Young and KPMG, Patrick worked and lived in Japan, Russia, France and Switzerland and has gained working knowledge of the respective income tax legislation in these countries. Patrick holds a BA from University of Colorado and is a member of the National Association of Enrolled Agents.

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, […]

Expatriated from US? New Procedure

On September 6, 2019, the Internal Revenue Service (IRS) announced a new procedure that allows certain non-compliant US citizens who relinquished their US citizenship to become US tax compliant. This procedure is geared towards ‘Accidental Americans’ who were unaware of their US tax obligations. Under this procedure, no US social security number is required. The […]

US Treatment of Swiss Pensions – 2nd pillar

The Swiss employee pension plan (known as the 2nd pillar pension), is, from a US tax perspective, a funded non-qualified foreign pension plan.  As such, contributions employees make to the plan are non-deductible from a US perspective and the company contributions to employee plans are considered taxable wages. We include the growth in the plan as […]

5 Ways Uncle Sam Can Still Reach Non-Resident Aliens

So, you feel lucky that you are not an American citizen, with the tax headaches that a citizenship-based system bestows upon the not so lucky US expatriate. Not so fast. Even though you are not an American, you may not be safe from Uncle Sam’s long tax arms. Below are five instances where he could still […]

US Expatriation: Look before you leap

We have blogged in the past about the general expatriation rules and proposed regulations concerning covered expatriates. Today, we thought we would dig a little deeper and alert the reader to some specific issues that they should be aware of prior to giving up their US citizenship. First and foremost, one should take steps to […]

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