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Search: Posts Made By: Scotsman In Texas
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Forum: USA
Oct 18th 2018, 5:03 pm
Replies: 2
Views: 1,048
Posted By Scotsman In Texas

Financial audit pre-move

Hi,

Anyone recommend an accountant/adivisor who could help a portguese friend of mine on a US tax audit prior to becoming a US-person? Need someone that could look out for PFICs/foreign...
Forum: USA
Jun 13th 2018, 5:37 pm
Replies: 5
Views: 1,809
Posted By Scotsman In Texas

Re: Is this a PFIC

Rathbones may not be a PFIC. It depends how they make their money. From what I know of them they are investment managers so would make their money on investment management fees. This is an active...
Forum: USA
Dec 4th 2017, 2:01 am
Replies: 2
Views: 1,547
Posted By Scotsman In Texas

Re: Any advantage converting my Stakeholder Pension to a SIPP?

Thanks! That’s really interesting and first time I have seen the actual piece of tax code that relates to UK pensions. The 50% rule seems particularly nebulous and hard to track, particularly for...
Forum: USA
Nov 18th 2017, 2:57 pm
Replies: 2
Views: 1,547
Posted By Scotsman In Texas

Any advantage converting my Stakeholder Pension to a SIPP?

I have a stakeholder pension from years ago when I lived in the UK. I have not made contributions for years. The position I have taken is that I claim a treaty exemption for the pension, and report...
Forum: USA
Oct 21st 2017, 10:47 am
Replies: 23
Views: 2,497
Posted By Scotsman In Texas

Re: GBP denominated accounts in USA?

Transferwise’s borderless account is interesting. This is a great service for international transfers, but looks like a really cost effective way to hold foreign currencies:...
Forum: USA
Oct 18th 2017, 2:16 pm
Replies: 23
Views: 2,497
Posted By Scotsman In Texas

Re: GBP denominated accounts in USA?

Thanks Steve. Very interesting. And yes, I am aware of the new IHT rules. It applies to residential property, everything else (such as land - which is a large chunk of the value here) will be...
Forum: USA
Oct 11th 2017, 9:16 am
Replies: 23
Views: 2,497
Posted By Scotsman In Texas

Re: GBP denominated accounts in USA?

It’s a US familiy limited partnership that holds a UK asset (a farm). Lots of benefits including a reduction in UK inheritance tax liability, US compliance as well as an easier way to gift asset to...
Forum: USA
Oct 10th 2017, 2:16 am
Replies: 23
Views: 2,497
Posted By Scotsman In Texas

Re: GBP denominated accounts in USA?

Thank you Mercury39 that's exactly what I need. Very helpful.



Absolutely not trying to avoid of US laws! Any account domiciled in the US has no FBAR requirement. I want an account domiciled in...
Forum: USA
Oct 9th 2017, 9:03 pm
Replies: 23
Views: 2,497
Posted By Scotsman In Texas

Re: GBP denominated accounts in USA?

When I say liabilities I mean there are huge potential penalties for failure to report a foreign bank account on both FBAR and potentially 8938 as I am sure you all know. Yet another potential for an...
Forum: USA
Oct 9th 2017, 6:58 pm
Replies: 23
Views: 2,497
Posted By Scotsman In Texas

GBP denominated accounts in USA?

Anyone know of any GBP-denominated accounts that are located in the US (and therefore don’t have FBAR reporting requirements) but can still be used like a standard bank account in the UK with...
Forum: USA
Apr 17th 2017, 5:09 pm
Replies: 65
Views: 24,213
Posted By Scotsman In Texas

Re: Fbar and 8938 nightmare

I think you need to have three posts to use the private message system. Perhaps it works now?

In answer to your question, it was a paper filing (which I think amended returns have to be). I...
Forum: USA
Apr 17th 2017, 12:31 pm
Replies: 65
Views: 24,213
Posted By Scotsman In Texas

Re: Fbar and 8938 nightmare

Yes - from me. Maybe if you add your email address to your profile I can send you an email?i think there are some new user restrictions on Private Messages.
Forum: USA
Mar 6th 2017, 5:11 pm
Replies: 65
Views: 24,213
Posted By Scotsman In Texas

Re: Fbar and 8938 nightmare

It highlights what an absurdity the 'miscellaneous offshore penalty is': assigning an arbitrary penalty on the fair market value of the overseas assets that are reported on FBAR and 8938. Even...
Forum: USA
Mar 4th 2017, 6:15 pm
Replies: 65
Views: 24,213
Posted By Scotsman In Texas

Re: Fbar and 8938 nightmare

Thanks - your thoughts are helpful. I might add that my experience with tax attorneys (at least the ones I have worked with) was that they were very reluctant to give me any measure of risk,...
Forum: USA
Mar 3rd 2017, 8:38 pm
Replies: 65
Views: 24,213
Posted By Scotsman In Texas

Re: Fbar and 8938 nightmare

Another update for anyone interested (or in a similar position). A happy ending.

It took around 6 months but the IRS have now processed my three amended returns filed under the delinquent...
Forum: USA
Nov 5th 2016, 2:07 am
Replies: 65
Views: 24,213
Posted By Scotsman In Texas

Re: Fbar and 8938 nightmare

Hey Simon, I sent you a PM. Happy to share what learnings I have had. Cheers.
Forum: USA
Oct 30th 2016, 11:11 am
Replies: 65
Views: 24,213
Posted By Scotsman In Texas

Re: Fbar and 8938 nightmare

To me the most costly part of this was the amount of time I had to devote to it: the interference in my day job and in my family life (wife and 3 kids under 5). The sheer volume of work, reporting...
Forum: USA
Oct 29th 2016, 1:56 pm
Replies: 65
Views: 24,213
Posted By Scotsman In Texas

Re: Fbar and 8938 nightmare

In case it helps anyone, I wanted to update on my progress on fixing up my international tax compliance problems. It has certainly been a journey over the last 6 months that I don't want to repeat....
Forum: USA
Sep 15th 2016, 6:01 pm
Replies: 1
Views: 713
Posted By Scotsman In Texas

Re: Form 720 for UK life insurance

Well, I answered one of my questions: there's something called a 720X for amended submissions. The question is, what to amend and how far back to go?
Forum: USA
Sep 13th 2016, 12:04 am
Replies: 1
Views: 713
Posted By Scotsman In Texas

Form 720 for UK life insurance

I have 3 UK life insurance policies, one with a small surrender value. The latter is reported on 8938 & FBAR. Policies are paid annually. I have been a US tax payer since 2007.

I have never done a...
Forum: USA
Aug 16th 2016, 5:55 pm
Replies: 65
Views: 24,213
Posted By Scotsman In Texas

Re: Fbar and 8938 nightmare

Here's my response from my accountant:


Anyone have a challenge to this?
Forum: USA
Aug 6th 2016, 6:48 am
Replies: 65
Views: 24,213
Posted By Scotsman In Texas

Re: Fbar and 8938 nightmare

As my particular policy is written into trust to avoid the proceeds becoming part of my estate, it becomes a foreign grantor trust. So looks like I should do a 3520 and a 3520-A every year, as well...
Forum: USA
Aug 5th 2016, 3:17 pm
Replies: 65
Views: 24,213
Posted By Scotsman In Texas

Re: Fbar and 8938 nightmare

Even at £50 per 8961 it would still be crazy for me. There's a substantial amount of work in each one.
Forum: USA
Aug 5th 2016, 9:28 am
Replies: 65
Views: 24,213
Posted By Scotsman In Texas

Re: Fbar and 8938 nightmare

I need to keep sharing this extraordinarily absurd journey I am taking into the bowels of the IRS.


This was confirmed by the IRS and so the default 1291 calculations are required under...
Forum: USA
Jun 29th 2016, 3:10 pm
Replies: 65
Views: 24,213
Posted By Scotsman In Texas

Re: Fbar and 8938 nightmare

Thanks all for the input. It makes me cry too that my previous accountant was so clueless, and has caused a considerable amount of anxiety. He should never have touched an international return.


...
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