IRS: Offshore Banks Will Need to Disclose Precious Metals Held by U.S. Clients

Earlier this week, I participated in to a teleconference sponsored by the Society of Trust and Estate Practitioners and the International Law section of the American Bar Association. The conference addressed the expanded offshore asset disclosure requirements brought into effect by the Foreign Account Tax Compliance Act (FATCA). (For background on FATCA  see here, here.)

Read MoreIRS: Offshore Banks Will Need to Disclose Precious Metals Held by U.S. Clients

The Taxpayer Advocate Service and the IRS

Occasionally, the U.S. Congress discovers to its great surprise that the agency it created to collect revenues for the federal government, the Internal Revenue Service, engages in systematic abuse of taxpayers. In one such moment in 1979, Congress created the Office of the Taxpayer Ombudsman as a taxpayer advocate within the IRS. This office eventually became the Taxpayer Advocate Service (TAS). by authority of first so-called "Taxpayer Bill of Rights" in 1988.

Read MoreThe Taxpayer Advocate Service and the IRS

Form 8938: Another Nail in the Coffin of Offshore Financial Privacy [Part I]

Are you a U.S. citizen or U.S. resident alien who held assets outside the USA at any time during 2011?  If so, you need to know about a rapidly approaching deadline for filing Form 8938, "Statement of Specified Foreign Financial Assets." Non-resident aliens may need to file this return as well in certain circumstances. See the instructions for Form 8938 for details.

Read MoreForm 8938: Another Nail in the Coffin of Offshore Financial Privacy [Part I]

Live Offshore and Earn Nearly $200,000 Annually, Tax-Free

The United States is one of the very few countries, and the only major country, that taxes its citizens, no matter where they live. If you haven't lived in the United States in decades, you must pay tax on your worldwide income as if you never left. Even "accidental" U.S. citizens born overseas with at least one U.S. parent, who never set foot in the United States, must file U.S. tax returns. Beneficiaries of a deceased U.S. citizen living abroad must prepare a U.S. estate tax return and possibly pay estate tax, even if they're non-U.S. citizens who have never lived in the United States.

Read MoreLive Offshore and Earn Nearly $200,000 Annually, Tax-Free

Can Obama Send U.S. Citizens to Guantanamo Bay?

The blogosphere has been humming the last couple of weeks with condemnation of the 2012 National Defense Authorization Act. This bill, which funds U.S. military forces for the coming year, has a neat little provision tucked away in Sec. 1031.  It permits anyone the government claims is “a member of, or part of, al-Qaida or an associated force” to be held in military custody “without trial until the end of the hostilities authorized by the Authorization for Use of Military Force.” Including, according to numerous blog posts, U.S. citizens residing in the United States.

Read MoreCan Obama Send U.S. Citizens to Guantanamo Bay?

Another “Tax Attack” on U.S. Citizens Living Abroad

The United States is one of only two countries, and the only major country, that taxes its citizens, no matter where they live. If you haven’t lived in the United States in decades, you must pay tax on your worldwide income as if you never left. Even “accidental” U.S. citizens born overseas with at least one U.S. parent, who never set foot in the United States, must file U.S. tax returns. These laws affect every one of the more than 6 million U.S. citizens living abroad.

Read MoreAnother “Tax Attack” on U.S. Citizens Living Abroad

Form 8938: Not a Prelude to a Wealth Tax…This Time [Part I]

Back in 2010, President Obama signed the infamous Foreign Account Tax Compliance Act (“FATCA”). Among other provisions, FATCA provides that if you hold a “specified foreign financial asset” (SFFA), you must attach a disclosure statement to your income tax return for each year in which the aggregate value of all such assets exceeds $50,000, or a larger sum as directed by the IRS.

Read MoreForm 8938: Not a Prelude to a Wealth Tax…This Time [Part I]

Counterfeit Gold: How to Protect Yourself

In the last few months, I've noted increasing interest from clients wanting to take physical delivery of their precious metals holdings.  This appears to be a worldwide trend.  Colleagues in Switzerland, Hong Kong, and Singapore have informed me that many of the wealthiest investors in Asia and Europe are now demanding delivery of their gold holdings from bonded warehouses in London, Chicago, and elsewhere.

Read MoreCounterfeit Gold: How to Protect Yourself