January 2015

Are the Psychological Benefits of U.S. Citizenship An Adequate Justification For the Worldwide Taxation of Nonresident U.S. Citizens?
Listen I recently wrote a two-part series about the inadequate justification for the United States’ worldwide taxation of its nonresident citizens (Part I is available here; Part II is available here). Professor Michael S. Kirsch offers a different perspective in defense of this system. Instead of assessing the propriety of U.S. worldwide taxation on the …
Don’t Mistake “GIIN” For Gin Or You May Suffer More Than Just a Hangover!
Listen In a recent blog entitled, “FATCA GIIN January 2015 FFI Registration Analysis … by the numbers,” Professor William Byrnes provides a brilliant commentary on the IRS’s publication of its first FATCA GIIN list of the new year (published on New Years Day!). The FATCA GIIN list is a list of “approved FFIs (Foreign Financial Institutions)” that have …
Application of Foreign Earned Income Exclusion to Civilian Contractors Working In Combat Zones (Part II)
Listen This is Part II of a two-part blog series. After establishing that they have a tax home in a foreign country, taxpayers must still establish that they satisfy the 330 day physical presence test or the bona fide residence test. See IRC section 911(d)(1). I. 330 Day Physical Presence Test The 330 day physical …
Application of Foreign Earned Income Exclusion to Civilian Contractors Working In Combat Zones (Part I)
Listen This blog addresses the foreign earned income exclusion rules as they apply to civilian contractors, and other civilian employees, who work in foreign country combat zones. By “civilian,” I am specifically referring to individuals who are not employees of the United States or any agency of the United States. I. IRC Section 911 Foreign …
What Should A Swiss Banker Charged With Offshore Tax Evasion Do In The Wake of Raoul Weil’s Astonishing Acquittal?
Listen The acquittal of Raoul Weil, the only Swiss banker to have prevailed over the U.S. government in an offshore tax evasion case, has become a source of inspiration for dozens of others who find themselves in a similar situation – indicted and living in Switzerland. As a result, many have become emboldened to come …