Why Are Lawyers So Expensive? I’ll Tell You Why

We are often asked why lawyers are so expensive and many times it is very difficult to fully explain the level of service you can expect when you hire an attorney. However, Sam Glover, in his article, posted on lawyerist.com, does a very fine job of detailing the level of service you can expect when […]

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Estate Taxes on US Vacation Home

If a non-domiciliary, non US-Person dies while owning US property (such as real estate), such property is generally subject to US estate taxation. So too, for example, will a German citizen and resident be subject to US Estate taxes if he invests in a US Vacation Home and then dies. In the United States, the […]

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Resident Streamlined Program – Waiver of Rights?

Effective July 1, 2014, the Internal Revenue Service created a new streamlined program for US Persons to become compliant with their income tax filing and Foreign Bank Account Reporting (FBAR) obligations. This Program is an alternative to the Offshore Voluntary Disclosure Program. We had previously discussed the program intended for Taxpayers residing outside the United […]

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A Glimmer of Hope – Non-Resident Streamlined Program

Effective July 1, 2014, the Internal Revenue Service created a new streamlined program for US Persons to become compliant with their income tax filing and Foreign Bank Account Reporting (FBAR) obligations. These Programs are an alternative to the Offshore Voluntary Disclosure Program and come in two flavors. The First is intended for Taxpayers residing outside […]

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Cautionary Tale for Those who Wait!

Those who wilfully fail to file the required foreign bank account reporting forms (FBARs) under the Bank Secrecy Act of 1970 and declare the income earned from those accounts on their income tax returns are being pressured from all sides to participate in the Offshore Voluntary Disclosure Program (OVDP). On one hand, foreign banks are […]

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Mere Failure to File a Form May Lead to Expatriation Taxes

If a taxpayer has been a legal permanent resident of the United States in eight of the last 15 years, then such taxpayer must inquire if he is subject to the expatriation tax regimes upon relinquishment of their “Green Card.” The main threshold amounts to being subjected to the expatriation tax regimes are (1) if […]

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Giving Up a “Green Card” Does Not Protect from Expatriation Tax Regimes

The current climate of increased enforcement of foreign bank account reporting and the increased complexity of complying with various information reporting under United States Laws has resulted in many people inquiring into relinquishing their Permanent Residence (“Green”) card. Such a move requires not only that proper immigration laws are followed by also requires proper tax […]

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Unexpected Suprise at Closing (FIRPTA)

The sale of a home, owned by a person who is not an income tax resident of the United States is relatively painless. It is important to remember, though, that the sale of US Real Property is generally taxable in the United States and thus, the seller generally is required to file an income tax […]

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Treaty Tie-Breaker Relief

If a taxpayer becomes a US Resident Alien for tax purposes because he holds a green card or has remained in the United States in excess of 182 days in any one year, then he ordinarily becomes subject to US taxation on his worldwide income. If the taxpayer is a resident of a nation that […]

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