US Tax Residency & Living Outside the US | International Tax Lawyer & Attorney Santa Monica CA Blog

Hello, and welcome to Sherayzen Law Office video blog. My name is Eugene Sherayzen and I am an international tax attorney and owner of Sherayzen Law Office, Ltd.

Today, I am continuing my series of vlogs from Santa Monica, California. If you recall, in a previous vlog, I raise the issue of US citizens moving to live outside of the United States. It seems like a good topic to pick, while in California. I’ve raised three main issues that should be considered by anyone who’s leaving the United States.

  1. Local tax compliance
  2. Ending state tax residency
  3. US international tax compliance

I addressed the first two issues in previous vlogs and today I’d like to begin addressing the third one. We’ll start with the income tax considerations. When you move outside of the United States, as long as you are a US citizen, you are considered to be a tax resident of the United States no matter to which country you move. Even if you move to North Korea, you still will be a tax resident of the United States.

What does it mean for you? It means that you have the obligation to continue to file US tax returns and to report your worldwide income on the tax returns.

We will continue discussing this topic in more detail in the follow-up vlogs.

Thank you for watching, until the next time.

Knowledge of FBAR Existence & Willfulness | FBAR Lawyer Beverly Hills Los Angeles California

Hello, and welcome to Sherayzen Law Office video blog. My name is Eugene Sherayzen and I am an international tax attorney and owner of Sherayzen Law Office, Ltd.

Today, we are continuing our series of vlogs from Beverly Hills, California and today I’d like to talk to you about FBAR compliance and particular where an obligation to file an FBAR was known to the taxpayer but the taxpayer has not acted on it. Is the taxpayer’s inaction in and of itself sufficient to automatically prove early non-compliance was willful and the answer is no, automatically no. We have to look at all facts and circumstances but is this a negative fact? Absolutely. The passage of time between the time when the taxpayer learned about the existence of FBAR and when he took action is a very important consideration, not only for the reasonable cause purposes, but also for non-willfulness purposes.

If you would like to learn more about FBAR compliance, in particular the issue of willfulness vs. non-willfulness, in the context of FBAR non-compliance, call me at (952) 500-8159 or you can email me at: [email protected]

Thank you very much and until the next time.

Worldwide Income Reporting while living outside the US | International Tax Lawyer

Hello, and welcome to Sherayzen Law Office video blog. My name is Eugene Sherayzen and I am an international tax attorney and owner of Sherayzen Law Office, Ltd.

We are continuing a series of blogs from Santa Monica, California. Today, I’m standing on the beach in front of the Pacific ocean and I’d like to talk to you about a topic I raised last time. Where I said if you decide to move outside of the United States, you continue to be a tax resident of the United States and you have to report your worldwide income on your US tax returns.

Today, I’d like to answer a few questions that often arise in the context of that statement. First of all: Does the worldwide income requirement mean that all of your income have to be disclosed or only elective income or passive income? The answer to that question is ALL income has to be disclosed; all foreign and domestic. It doesn’t matter if it’s subject to local taxation. It doesn’t matter whether it’s non-taxable in the local country. Here, you have to operate as a US tax resident by US tax rules, so all of your worldwide income is reportable on your US tax returns.

Does that mean that you won’t be able to take advantage of the fact that you are taxed locally? Does it mean that you will be suject to double taxation? Not necessarily. The United States has plenty of tax treaties around the world with many countries, the vast majority of countries and you should be able to take a foreign tax credit to minimize your US tax liability, though it may not be dollar for dollar, there may be complications which is an issue to be discussed in the context of specific facts but you’re likely not to be subject to full double taxation. There should be a way for you to plan out your tax affairs and a way to minimize your US tax exposure. We’ll continue exploring this subject of US international tax reporting requirements in the following blogs.

Thank you for watching, until the next time.