On November, 14 2013, the US and France signed a bilateral agreement to implement the Foreign Account Tax Compliance Act (FATCA). The agreement is based on the Model 1A treaty and requires French financial institutions to report US account holders to the French government, which will then report those accounts to the US. Similarly, US financial institutions are required…
DetailsFlott & Co. recently had the opportunity to discuss our proposal for changes to the existing IRS “noisy” disclosure programs (Offshore Voluntary Disclosure Program – OVDP – and the Streamlined Filing Compliance Procedure for Non-Resident US Taxpayers – Streamlined Process) with representatives of the Service. The discussion focused on encouraging the IRS to create a…
DetailsDEAR MR. HORTON: The Service’s approach to tax and FBAR compliance by US citizens who are dual nationals and long-term residents of other countries needs to change. The existing compliance programs do not reflect the demonstrable reality that there are many genuinely innocent delinquent US taxpayers living overseas. Enclosed with this letter is a proposal…
DetailsThis discussion of US citizenship is intended to cover persons who reside outside the United States and are uncertain about their US citizenship status.[1] Essentially, those who were born in the United States are citizens. Those who were born outside the United States to one or two US citizen parents are certainly entitled to US…
DetailsThe IRS applies different methodologies for calculating the gambling winnings of US taxpayers and Nonresident Aliens (NRAs). For US taxpayers, the IRS calculates earnings based on winnings over the course of a gambling session, while for NRAs the IRS has taken the position that gambling winnings should be calculated based on each bet. So, for…
DetailsDuring 2012, the tax consequences of U.S. citizenship became a major source of worry for U.S. citizens living in Canada. Widespread reports in the media of increased U.S. enforcement of the tax and financial account reporting obligations of U.S. citizens living outside the United States created considerable anxiety. They also spurred questions about the particulars…
DetailsDuring 2012, the tax consequences of U.S. citizenship became a major source of worry for U.S. citizens living in Canada. Widespread reports in the media of increased U.S. enforcement of the tax and financial account reporting obligations of U.S. citizens living outside the United States created considerable anxiety. They also spurred questions about the particulars…
DetailsThis post will describe several common US citizenship situations for the purpose of demonstrating the various differences as to how US citizenship may be derived and how it may be lost. Ms. X was born in the United States. She is a US citizen by birth. Her US citizenship is self-executing and non-consensual. Her birth…
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