International Tax Blog

2019 2nd Quarter Published Expatriates

Today the Treasury Department published the names of individuals who renounced their U.S. citizenship or terminated their long-term U.S. residency (“expatriated”) during the second quarter of 2019. The number of published expatriates for the quarter was 609. See the chart below for the quarterly expatriates from 2008 to the second quarter of 2019. For a discussion of how the IRS compiles the data, see this post. For our prior coverage of expatriation, see all posts... Read more →

India-U.S. Income Tax Treaty – Article 12, Fees For Included Services

Sometimes U.S. companies perform services in the U.S. for customers located in India and are surprised when the Indian customer withholds Indian taxes from the payment for those services. Most U.S. income tax treaties would not allow foreign taxes to be imposed on services performed in the U.S., where the U.S service-provider has no activity or permanent establishment in the foreign country. However, the India-U.S. Income Tax Treaty (the “Treaty”) is not a typical U.S.... Read more →

Famous Tax Quote - Forming HoldCo To Acquire Target Is Not Unusual

Famous Tax Quotes includes quotations from court opinions with language that is colorful or that concisely states an important tax principle. Continuing our series on Famous Tax Quotes, today's Famous Tax Quote is: The formation of a holding company to acquire another corporation is not an unusual procedure * * *. Cromwell Corp. v. Commr., 43 TC 313 (1964) Read more →

Famous Tax Quotes - A taxpayer’s own documents

Famous Tax Quotes includes quotations from court opinions with language that is colorful or that concisely states an important tax principle. Continuing our series on Famous Tax Quotes, today's Famous Tax Quote is: [A]lthough a taxpayer’s own documents are not conclusive, they normally override any conflicting subjective considerations advanced by that taxpayer. Redwing Carriers, Inc. and Rockana Carriers, Inc., v. Laurie W. Tomlinson, former Director of Internal Revenue for the District of Florida, 399 F.2d... Read more →

U.S. Government Continues to Pursue Taxpayers Committing Tax Fraud

As we have reported in past years the U.S. government actively pursues taxpayers that are committing tax fraud and other tax crimes. The Justice Department publicizes its successes in its press releases. The press releases continue to demonstrate an impressive list of tax-related convictions, guilty pleas, injunctions, summonses, and other actions against taxpayers (and tax preparers). Many of the tax fraud schemes include offshore activities. See, for instance: Court Authorizes Service of John Doe Summonses... Read more →

2019 1st Quarter Published Expatriates - 1,019 Names

Today the Treasury Department published the names of individuals who renounced their U.S. citizenship or terminated their long-term U.S. residency (“expatriated”) during the first quarter of 2019. The number of published expatriates for the quarter was 1,019. See the chart below for the quarterly expatriates from 2008 to the first quarter of 2019. The numbers seem to have leveled off at roughly 1,000 expatriations per quarter. For a discussion of how the IRS compiles the... Read more →

Section 911 Housing Cost Amounts Updated for 2019

Last week the IRS published Notice 2019-24 which provides adjustments to the limitation on housing expenses for specific locations in 2019. Code §911(a) allows a qualified individual to elect to exclude from gross income an “Exclusion Amount” related to foreign earned income and a “Housing Cost Amount.” The Exclusion Amount for 2019 is $105,900. The Housing Cost Amount is generally defined as an amount equal to the excess of (A) the “Housing Expenses” of an... Read more →

Code §911 Foreign Earned Income Exclusion - Adverse Conditions for 2018

Last week the IRS published Revenue Procedure 2019-15, which announced that Democratic Republic of the Congo, Cuba, Iraq, and Nicaragua are the countries for 2018 where it was determined that war, civil unrest, or similar adverse conditions precluded the normal conduct of business for purposes of Code § 911. The effective date for Democratic Republic of the Congo was December 14, 2018, the effective date for Cuba was January 4, 2018, the effective date for... Read more →

New IRS Practice Units published in March

Last week the IRS released 3 new practice units titled: Competent Authority Revenue Procedure 2015-40 Guidance: Foreign-Initiated Adjustment(s) (03-21-2019) Introduction to Traditional Automatic Exchange of Information (03-15-2019) Competent Authority Process Under a MAP Article of a U.S. Income Tax Treaty (03-08-2019) We updated our IRS Practice Units By Topic page to add these new practice units. Read more →

2018 4th Quarter Published Expatriates - A total of 685

Today the Treasury Department published the names of individuals who renounced their U.S. citizenship or terminated their long-term U.S. residency (“expatriated”) during the fourth quarter of 2018. The number of published expatriates for the fourth quarter was 685, bringing the total number of published expatriates in 2018 to 3,981. The number of expatriates for 2018 is a 22% decrease from 2017. For our prior coverage of expatriation, see all posts tagged Expatriation. Read more →