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Search: Posts Made By: TXLonghorn
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Forum: USA
Mar 4th 2017, 5:11 am
Replies: 65
Views: 24,243
Posted By TXLonghorn

Re: Fbar and 8938 nightmare

Both an attorney and CPA told you that a property sale abroad is not taxable?? That's tax 101 basics. That's gross incompetence and probably malpractice. It's really not that complicated to report...
Forum: USA
Mar 4th 2017, 3:03 am
Replies: 65
Views: 24,243
Posted By TXLonghorn

Re: Fbar and 8938 nightmare

If you are able to establish reasonable cause, then the delinquent international filing procedures is a good alternative to SDOP.

I agree on being pragmatic and not over-googling things. People...
Forum: USA
Feb 26th 2017, 9:09 pm
Replies: 27
Views: 1,974
Posted By TXLonghorn

Re: Help with a tax problem

Well I guess we were not talking about the same things. By gov't pension I was referring to a UK workplace pension set up by the government, not a civil service pension.
Forum: USA
Feb 26th 2017, 6:07 pm
Replies: 27
Views: 1,974
Posted By TXLonghorn

Re: Help with a tax problem

I hope that no one takes any such information posted by anyone on an online discussion board at face value. I have not done my due diligence on this obviously because he is not a client. And I will...
Forum: USA
Feb 26th 2017, 6:00 pm
Replies: 27
Views: 1,974
Posted By TXLonghorn

Re: Help with a tax problem

That applies only to UK government employee pensions. Notice it says services performed for and not in.

Pensions paid by, or funds created by, the
United Kingdom, its political subdivisions, or...
Forum: USA
Feb 26th 2017, 5:22 am
Replies: 27
Views: 1,974
Posted By TXLonghorn

Re: Help with a tax problem

Wrong again. The term "national" in the OECD is left up to the individual country to define. For tax treaty purposes, the term "national" includes permanent residents. The whole purpose of the...
Forum: USA
Feb 25th 2017, 7:20 pm
Replies: 27
Views: 1,974
Posted By TXLonghorn

Re: Help with a tax problem

Actually, this is false. Apparently you're not familiar with the savings clause of the treaty. You may want to refer to the technical explanations of the treaty.

"The benefits referred to are all...
Forum: USA
Feb 25th 2017, 5:27 pm
Replies: 27
Views: 1,974
Posted By TXLonghorn

Re: Help with a tax problem

Fair enough, but you do realize there's a 1040NR for non-residents right? In this case he doesn't have US sourced income so he wouldn't have an 1040NR requirement.
Forum: USA
Feb 25th 2017, 5:25 pm
Replies: 27
Views: 1,974
Posted By TXLonghorn

Re: Help with a tax problem

If you received UK gov't pension while a US citizen or Perm Resident, the income is taxable in the U.S. per the savings clause of Article 1 of the US/UK tax treaty. However you can claim foreign tax...
Forum: USA
Feb 25th 2017, 4:20 pm
Replies: 27
Views: 1,974
Posted By TXLonghorn

Re: Help with a tax problem

How long have you been a US tax resident? Have you been filing your 1040s during that time?
Forum: USA
Feb 25th 2017, 4:13 pm
Replies: 65
Views: 24,243
Posted By TXLonghorn

Re: Fbar and 8938 nightmare

You'll probably have to file under the streamlined offshore compliance procedures. All I can say is stay away from Greenback. I've had clients come to me after using Greenback and their tax returns...
Forum: USA
Dec 13th 2016, 6:28 pm
Replies: 43
Views: 11,179
Posted By TXLonghorn

Re: Letter from UK bank - Tax Residence Status

You can comply or not; it shouldn't make a difference as the values are below the FBAR reporting threshold and you're not earning any interest income.

These letters are normal, but I haven't seen...
Forum: USA
Dec 13th 2016, 6:24 pm
Replies: 20
Views: 2,112
Posted By TXLonghorn

Re: Mortgage for Landlord living abroad

If you sell it within 3 years from the date you stopped using it as your primary residence, the gain should be excluded under IRC 121.

I hope that you are reporting the rental property on the US...
Forum: USA
Dec 1st 2016, 12:44 pm
Replies: 33
Views: 3,383
Posted By TXLonghorn

Re: Dual US/UK Citizen Tax Question

When the taxpayer lives abroad willfullness is hard to prove. He lives and works in the UK and has ties there. It would make sense that he has foreign accounts and assets there for perfectly...
Forum: USA
Dec 1st 2016, 12:39 pm
Replies: 33
Views: 3,383
Posted By TXLonghorn

Re: Dual US/UK Citizen Tax Question

Reasonable cause is part of the streamlined agreement. First time abate is for a one time failure to file/failure to pay. It requires a three year clean compliance history (which if he has not filed...
Forum: USA
Dec 1st 2016, 11:40 am
Replies: 33
Views: 3,383
Posted By TXLonghorn

Re: Dual US/UK Citizen Tax Question

I don't know what decently safe means. It's either willful or not. Doesn't seem to me to be willful based on the limited facts. OVDP (another option) seems like overkill and carries a 27.5% penalty.
Forum: USA
Dec 1st 2016, 3:27 am
Replies: 33
Views: 3,383
Posted By TXLonghorn

Re: Dual US/UK Citizen Tax Question

Here's some more information for you: https://www.irs.gov/individuals/international-taxpayers/streamlined-filing-compliance-procedures

Note that there are two streamlined offshore procedures -...
Forum: USA
Dec 1st 2016, 3:13 am
Replies: 33
Views: 3,383
Posted By TXLonghorn

Re: Dual US/UK Citizen Tax Question

First, take everything you read here regarding taxes with a grain of salt. I've seen so much bad information posted here.

Second, don't just file the returns and FBARs (AKA silent filing). If...
Forum: USA
Dec 1st 2016, 1:35 am
Replies: 10
Views: 819
Posted By TXLonghorn

Re: US Taxes if in the US for a substantial period within a year

And Steve, I'm sorry but you are dead wrong. He still needs to file a 1040NR to report income earned in the US. The closer connection simply means he is not a US resident for tax purposes - i.e.,...
Forum: USA
Dec 1st 2016, 1:30 am
Replies: 10
Views: 819
Posted By TXLonghorn

Re: US Taxes if in the US for a substantial period within a year

See IRC 301.7701(b)-2(d)(1) and Podd v. Commissioner for a list of facts and circumstances to see if you'll meet the closer connection test. Generally closer connection should be a last resort if...
Forum: USA
Nov 4th 2016, 4:37 pm
Replies: 125
Views: 11,844
Posted By TXLonghorn

Re: What exactly is better about the US?

This comment hints at a bit of ignorance likely due to a lack of experience and perspective. As a person who grew up in a 3rd world country, I can tell you that it is possible to improve your life...
Forum: USA
Nov 4th 2016, 6:11 am
Replies: 125
Views: 11,844
Posted By TXLonghorn

Re: What exactly is better about the US?

Sounds like your job situation might be clouding your view. When you're unhappy with your job, life is unbearable. Do something you enjoy. That's the great thing about the US. If there's a will,...
Forum: USA
Nov 4th 2016, 5:50 am
Replies: 15
Views: 1,295
Posted By TXLonghorn

Re: First Tax Return / Medical Insurance Gross Income Requirement

I think the Mar through Dec question has already been answered, but I just wanted to add something. You're correct that you will only include worldwide income from Mar through Dec. From Jan through...
Forum: USA
Nov 1st 2016, 3:47 am
Replies: 15
Views: 1,199
Posted By TXLonghorn

Re: Bank stopped taking federal witholding from Savings account interest

If the withholding stopped, then you probably filled out a Form W-9 which is the correct form. You mentioned that you are a US resident for tax purposes. A US resident is not subject to backup...
Showing results 1 to 24 of 24


 
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