Advantageous Abandonment of a U.S. Green Card
If you have the status of lawful permanent resident of the United States (i.e., you are a “green card” holder), and you reside in the United Kingdom, and you intend to abandon your green card, you...
View ArticleInternal Revenue Code § 965 and the Streamlined Procedures
Internal Revenue Code § 965, as added by the Tax Cut and Jobs Act of 2017, requires a controlled foreign corporation (“CFC”) to include in its Subpart F income its post-1986 accumulated but previously...
View ArticleForeign Accounts Compliance Update
Immigration to the United States continues at a strong pace. The people coming over tend to be members of the technical, educated class, from countries like India. We are also seeing many people...
View ArticleUnited States Income Taxation Of United Kingdom-Based Pension Plans
Many United Kingdom citizens retire in the United States after working in the United Kingdom. Such individuals’ interests in United Kingdom-based pension plans raise complex issues of United States...
View ArticleExpatriation From The United States
Renunciation of United States citizenship or abandonment of United States lawful permanent resident (“green card”) status is a major event in an individual’s life. Nonresidents of the United States...
View ArticleMichigan Durable Powers Of Attorney
.indented { padding-left: 50pt; padding-right: 50pt; } An elderly woman living alone suffers a stroke, and falls. Later, at a rehabilitation facility, the woman falls again, this time suffering a...
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View ArticleSupreme Court Signals Reversal in Bittner
On November 2 the Supreme Court held oral arguments in Bittner,[1] on whether the failure to timely file a Financial Crimes Enforcement Network Forms 114, “Report of Foreign Bank and Financial...
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Required Minimum Distributions
Internal Revenue Code (“IRC”) Section 403(b) annuities, Section 401(k) plans, and Section 408 individual retirement arrangements, whether individual retirement accounts or simplified pension plans,...
View ArticleForms 8938, 5471, 3520 3520-A, 5472, 8865, and 926 and Assessable vs....
In the recent case of Farhy v. Commissioner, the Internal Revenue Service assessed penalties against Alon Farhy for failing to file Form 5471, Information Return of U.S. Persons With Respect To...
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