Recent court holdings allowing the credit against the tax may encourage similarly situated taxpayers, but procedural hurdles must be cleared.
Expatriates
A proposal to end citizenship-based taxation for US citizens living overseas
A bill in Congress would allow U.S. citizens residing abroad to elect out of being taxed on their U.S. income.
Bidding farewell to US citizenship: Understanding the exit tax
Potentially costly and far-reaching tax liabilities of covered expatriates should give individuals pause before renouncing U.S. citizenship or permanent resident status.
IRS steps up enforcement of the individual expatriation tax
The Sec. 877A exit tax applies to specified expatriating U.S. citizens and long-term residents on gains from a deemed sale of assets. Expatriates’ numbers have risen, and the IRS is emphasizing compliance.
Engineer cannot escape closing agreement
A taxpayer cannot the avoid consequences of a closing agreement.
Foreign earned income exclusion: Pandemic-related relief
The IRS provides relief for taxpayers who would have qualified for the foreign earned income exclusion in 2019 and 2020 but for COVID-19.
Puerto Rico residents: Scope of income tax exemption for capital gains
The tax advantages available in Puerto Rico have recently captured the interest of both taxpayers and the IRS.
Tax treaties do not provide a foreign tax credit against net investment income tax
A U.S. taxpayer living abroad was not entitled to take a foreign tax credit against her net investment income tax based on provisions in the United States–France and United States–Italy tax treaties.
Unintended consequences of foreign branch reporting
Certain U.S. citizens and U.S. residents doing business abroad can have surprising tax reporting obligations as a consequence of the IRS’s revised instructions to Form 8858.
employee benefits & pensions
Profits interests: The most tax-efficient equity grant to employees
By granting them a profits interest, entities taxed as partnerships can reward employees with equity. Mistakes, however, could cause challenges from taxing authorities.