Foreign Nationals & Expats

U.S. Tax Treatment of U.K. Pension Plans

U.S. Tax Treatment of U.K. Retirement & Pension Plans Few things are more confusing for U.K. foreign nationals and U.S. expats residing in the U.K. than the U.S. tax code, especially as it applies to cross-border pensions. Here’s a short primer for the dazed and confused. Types of U.K. Pensions U.K. pensions can be grouped … Read more

How to Read Tax Treaties

How to Read Tax Treaties – Example IRA distribution for U.S. expat in the U.K. The United States has tax treaties with a number of foreign countries (link). Under these treaties, residents of foreign countries are taxed at a reduced rate, or are exempt from U.S. taxes on certain items of income they receive from … Read more

MMA Fighter in Court Battle re: FBAR Penalty Suit

FBAR Penalty Suit: U.S. v. Gracie et al A mixed martial artist and his spouse challenge over $210,000 in penalties for failing to report foreign bank accounts in  U.S. v. Royce Gracie and Marianen Cuttic (2:17-cv-3308). On the heels of last year’s Colliot and Wahdan decisions, Gracie and Cuttic filed for motion for partial summary judgment … Read more

Offshore Tax Compliance — How Fast are you Speeding?

Offshore Tax Compliance — How Fast are you Speeding? In my offshore tax compliance practice, I’ve talked to hundreds of individuals from around the world – from people who’ve unintentionally violated U.S. foreign financial and tax reporting laws to those who’ve knowingly or recklessly violated them. Two questions are invariably asked – “what are my risks, … Read more

Reporting Foreign Trusts

Reporting Beneficial Interest in a Foreign Trust & Form 3520 According to the IRS, foreign trusts are a major compliance issue: Citizens and residents of the United States are taxed on their worldwide income. To help prevent the use of foreign trusts and other offshore entities for tax avoidance or deferral, Congress has enacted several specific … Read more