Month: September 2015

By Sanford Millar of MillarLaw A Professional Corporation On Monday, September 21, 2015

There are now 50 foreign financial institutions on the IRS list of “bad banks” The list is published at the following link: http://www.irs.gov/Businesses/International-Businesses/Foreign-Financial-Institutions-or-Facilitators If a U.S. taxpayer has or had a foreign financial account that is unreported for FBAR purposes at any of the foreign financial institutions on the “bad bank” list the IRS and … Continue reading Bad Bad, Bad Penalty, Bad OVDP Policy

By Sanford Millar of MillarLaw A Professional Corporation On Monday, September 14, 2015

It may be a commone misunderstanding that a U.S. citizen or permanent resident (Green Card holder) can give up their citizenship or surrender their Green Card and  then as a non-U.S. taxpayer make gifts or pass their estate to U.S. taxpayers free of estate and gift tax.  The IRS recognized this loophole and has proposed … Continue reading Giving Up U.S. Citizenship – Estate and Gift Tax Traps