The days of US persons hiding their money in Swiss accounts is coming to a screeching halt. If a foreign bank account (specifically Swiss in this case) had at least $50,000 at any point since 2013 and it was not disclosed to IRS, keep reading as Swiss banks may be inadvertently tattling in the coming […]

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 […]

One of the first questions posed to us by local advisors (investment managers, law firms, accounting firms, trustees) and by their clients is, What is the definition of a US Person for tax purposes? The US tax system imposes its income tax on “US Persons”; and the tax reaches all forms of income and gains […]

The IRS is targeting high-income taxpayers who have not complied with their tax obligations. As part of a larger effort to ensure compliance and fairness, the Internal Revenue Service said on February 19th that it will step up efforts to visit high-income taxpayers who have failed to timely file one or more of their tax returns. The IRS has recently hired additional enforcement personnel, […]

The article below was written by USTAXFS Tax Director, Andrew Aldridge, in January 2020. It was first published in and is copyrighted by, Taxation magazine. The recent announcement by the Duke and Duchess of Sussex to step back from their ‘senior’ royal status has brought back into focus that the duchess is a US citizen. When […]

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 […]

On December 20, 2017, Congress passed H.R. 1 – the Tax Cuts and Jobs Act (TCJA) – providing for the largest changes to the US tax code since 1986 and President Trump signed the bill into law on December 22, 2017. As we have done previously, we have highlighted the changes made to US Federal […]