In the eyes of the IRS, there is no difference between Green Card Holders and US citizens for tax purposes. That is, Green Card Holders have the same tax reporting obligations as US citizens. A Green Card Holder is at risk of significant non-compliance depending upon the value… Read More

There are several ways to cure foreign bank account noncompliance. The primary method is the Streamlined Compliance Procedure. In order to qualify for the Streamlined Compliance Procedures, the taxpayer’s failure to disclose his or her foreign bank accounts must be non-willful, he or she must have timely filed… Read More

A Reasonable Cause argument may be asserted in defense of penalty assessments. It is a delicate and precise argument however and it takes knowledge of the Regulations, the Internal Revenue Manual (IRM) and relevant caselaw discussing Reasonable Cause. Within the IRM, Reasonable Cause is generally defined as: “reasonable… Read More

A taxpayer should report his or her foreign bank accounts annually, so long as the foreign accounts meet certain reporting criteria. There are generally two reporting obligations and both have different measures: one requirement is IRS Form 8938, Statement of Specified Foreign Financial Assets, to be filed with… Read More

Gifts from foreign persons to US persons may be reportable to the IRS and may be taxable. However, just because something is reportable does not mean it is automatically taxable. First, there are important monetary thresholds to keep in mind. A US person who receives – and treats… Read More