Category Archives: International

Can a Resident of a Non-Tax Treaty Country (With Respect to Gambling) Get His Withheld Funds Back?

Posted on February 9, 2016 by Russ

Today, I received an inquiry from a citizen of New Zealand (he is not a US citizen or permanent resident). He had done well in a poker tournament here in the United States–well enough to have had 30% of his … Continue reading →

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TIGTA: “IRS Can’t Track International Correspondence.” IRS: “So What.”

Posted on September 30, 2015 by Russ

The nature of my practice is such that I have a relatively large number of clients who live outside the United States. When one of my expatriate clients gets an IRS notice, I shudder. The IRS offices that handle international … Continue reading →

Posted in International, IRS | Tagged | 1 Comment

Neymar Tax Evasion Investigation Continues; Judge Freezes $48 Million of Assets

Posted on September 27, 2015 by Russ

Neymar is one of the world’s best soccer players. Given an injury to fellow Barcelona player Lionel Messi, there’s pressure on Neymar and his teammates to step up. Earlier this year it was disclosed that Neymar was being investigated for … Continue reading →

Posted in International, Tax Evasion | Tagged | 1 Comment

Not Remitting Employment Taxes Doesn’t Work in Japan Either

Posted on August 9, 2015 by Russ

In the United States, one of the quickest ways of getting in tax trouble is by withholding employment taxes and not remitting those taxes to the IRS. The rate of investigation is as close to 100% as you can get–and … Continue reading →

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Deadline Changes for 2016 Tax Returns and 2016 FBAR

Posted on August 2, 2015 by Russ

Congress passed and President Obama signed the Surface Transportation and Veterans Health Care Choice Improvement Act of 2015 in late July. That law’s primary function has nothing to do with tax; however, it will have a major impact on entity … Continue reading →

Posted in International, IRS | Tagged | 1 Comment

Does a Nonresident Alien Spouse that Has Elected to be Treated as a US Person Need to File an FBAR?

Posted on June 29, 2015 by Russ

With the FBAR deadline upon us, an interesting question arose: Does a spouse covered by the §1.6013-6 regulation allowing a nonresident alien individual to be treated as a resident need to file an FBAR? Logic says no; the FBAR comes … Continue reading →

Posted in FINCEN, International | Tagged | 1 Comment

BEA-10 Due on June 30th

Posted on June 24, 2015 by Russ

Just a reminder this morning that the BEA-10 mandatory survey of foreign investment by Americans is due on June 30th. If you own 10% or more of a foreign entity, you will need to file this form. New filers must … Continue reading →

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FBAR Due in One Week

Posted on June 23, 2015 by Russ

The Report of Foreign Bank and Financial Accounts (Form 114, the FBAR) is due on June 30th. The form must be electronically filed with FINCEN. Your tax professional may be able to do it through his software (we can) or … Continue reading →

Posted in Gambling, International | Tagged | 1 Comment

A Ship Over Troubled Waters Sinks Leeds’ Cellino For Now

Posted on December 1, 2014 by Russ

From the Sport (not Sports) page of the Telegraph and the BBC we find that Leeds beat league-leading Derby two to nil in football (or soccer for us colonials). Derby manager Steve McClaren was quoted by the BBC: “It’s just … Continue reading →

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Lawsuits Against FATCA in Canada

Posted on August 14, 2014 by Russ

A lawsuit was filed in Federal Court in Vancouver, British Columbia, challenging Canada’s complying with the US Foreign Account Tax Compliance Act (FATCA). This is the law that spawned Form 8938 (the “Son of FBAR”). This law, passed in 2010, … Continue reading →

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