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Author Archives: Patrick Hoza

US Estate Tax Concerns for Non-US Persons Update

USTAXFS Tax Director, Patrick Hoza, provides the latest on US Estate Tax concerns for non-US persons. The United States imposes its Estate Tax not only on its citizens and residents but also on non-residents that die owning US situs assets. So, what might be taxable? Non-resident aliens (NRAs) are taxed on certain categories of US […]

IRS Issues Guidance and Solicits Feedback on Nonfungible Tokens (“NFTs”)

On March 21, 2023, the Treasury Department and the Internal Revenue Service (the “IRS”) announced that they were requesting comments regarding upcoming guidance on US tax treatment of certain nonfungible tokens (“NFTs”) as collectibles under Internal Revenue Code (IRC) section 408(m). NFTs An NFT is a unique digital identifier that is used to certify ownership and […]

Pillar 2: A Deep Dive into the Swiss Pension System for American Expats

This Swiss Pillar article was produced in collaboration with Connected Financial Planning.  Occupational Pension or Work Pension This Pillar 2 plan is similar to the US 401(k) and 403(b) type plans. It is comprised of two parts:  1. Mandatory benefits (BVG-LPP) For those who are self-employed, you may choose to make voluntary contributions. If you […]

2022 US tax year changes: Individual, estate and gift taxes

The annual tax filing season opened on Monday this week, and we are delighted to summarize some important changes to the 2022 US tax year when compared to prior years. The most notable changes are: The first page of Form 1040 will look significantly different for the 2022 US tax year than prior years. There […]

2022 UK Autumn Statement: Are you affected?

The UK Chancellor, Jeremy Hunt, this morning delivered his much-anticipated Autumn Statement. He promised a “balanced plan for stability” and asked, “those with more to contribute more”.  He started by setting out the changes to personal taxes. There were no surprises here as these had been trialled in the media over the last week. The […]

US Tax Compliance For Foreign Trusts

When handling the US tax implications of trusts, particularly non-US trusts, there are a number of issues you must address: Is the entity a trust for US tax purposes? If the entity is a trust, is it a US (domestic) trust or a non-US (foreign) trust? If the entity is a trust, is it a […]

IRS Scams Investigations to include Pensions, Insurance & Digital Currency

For about 20 years now, the IRS has been annually publishing a ‘Dirty Dozen’ list of common taxpayer “scams.” The intent is to warn taxpayers, tax professionals, financial institutions, and financial advisors of abusive transactions, including bogus tax avoidance strategies as well as consumer-focused scams that target average taxpayers. The IRS identifies problem areas through audits, promoter […]

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