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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.

Proposed Regulations Issued on Covered Gifts or Bequests

On September 9, 2015, the IRS issued notice of proposed rule-making (NPRM) 112997-10. It relates to 2008 legislation regarding Section 2801 – gifts to US persons (US citizens, US residents or domestic trusts) made by former US citizens and long-term residents who expatriate after June 16, 2008, and are classified as ‘covered expatriates.’ Below we […]

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