Category Archives: International

When Bad Recordkeeping Helps You (And Bad News for Some Canadian Professional Poker Players)

As we previously reported, the Canada Revenue Agency (CRA) thought that Jonathan Duhamel, the winner of the Main Event of the World Series of Poker (WSOP) in 2010 was a professional gambler, and that he conducted himself as a professional … Continue reading

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Is It One Penalty of $10,000 or Multiple Penalties of $10,000?

Suppose you are a resident of a foreign country–say, Romania–and you have foreign financial accounts.  You need to file the FBAR (Report of Foreign Bank and Financial Accounts) to tell the Financial Crimes Enforcement Network (FINCEN) what foreign accounts you … Continue reading

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Bozo Tax Tip #7: Only Income Earned Outside the United States Is Taxable

A few days ago I was explaining to a client the basics of the US Tax Code: All income is taxable unless Congress exempts it; nothing is deducible unless Congress allows it. That’s the basics. My office is in Las … Continue reading

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Online Gambling and Cryptocurrency Addresses for 2022

[This listing has been replaced by the 2023 listing.] If you have one or more foreign financial accounts and you have $10,000 aggregate in those account(s) at any time during 2019, you must file the Report of Foreign Bank and … Continue reading

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The K-2/K-3 Kerfuffle

The IRS announced a year ago that there would be two new forms for partnerships and S-Corporations with international income and/or partners: Schedules K-2 and K-3 (links are to the partnership versions of these forms).  Most tax professionals would have … Continue reading

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The 2021 Tax Offender of the Year

It’s time once more for that (not really) most prestigious of prestigious awards, the Tax Offender of the Year.  One year I’ll find that I don’t have many deserving winners (probably the year after I retire); however, there were plenty … Continue reading

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Bozo Tax Tip #7: Use a Foreign Trust to Avoid Taxes!

By far the worst tax schemes in the view of the IRS are offshore (foreign) trusts. In fact, trusts of all sorts—domestic and foreign—are regularly abused. First, not all trusts are bad. Many trusts serve a legitimate purpose, such as … Continue reading

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Bozo Tax Tip #8: The Shell

I was talking with a friend who is an attorney in the Midwest. She told me about an individual who decided to use ten layers of shell companies to hide his income. It worked so well that the Bozo had … Continue reading

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Online Gambling and Cryptocurrency Addresses for 2021

If you have one or more foreign financial accounts and you have $10,000 aggregate in those account(s) at any time during 2019, you must file the Report of Foreign Bank and Financial Accounts (the “FBAR”). This is Form 114 from … Continue reading

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Clarity on Whether Cryptocurrency Must be Reported on the FBAR

A vexing question has been whether or not foreign cryptocurrency exchanges must be reported on the FBAR. At a conference in 2019, a representative from FINCEN said no; however, the instructions on the FBAR imply they should be reported. At … Continue reading

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