The U.S. and Malta have signed an agreement that will end the alleged mis-use of certain provisions in the existing U.S./Maltese income tax treaty by Americans seeking to avoid paying tax on income generated by pension schemes domiciled there, the Internal Revenue Service said this week.

As regular readers of the American Expat Financial News Journal possibly know better than most, U.S. taxpayers who live abroad (as well as their tax advisers) are increasingly having to consider the potential interactions between U.S. and foreign laws when determining the U.S. tax consequences of a particular financial transaction.

U.S. tax expert Virginia La Torre Jeker explains it this way: "In today's world, it is no longer possible for practitioners to ignore the possible implications of another country’s laws."

As this and other news organizations reported back in February, more Americans handed their citizenships back to Uncle Sam in 2020 than during any other single year to date, in spite of the fact that U.S. embassies and consulates around the world – which are needed to process such citizenship renunciations – were closed or offering reduced services for most of the year...

Last week, we reported the news that the U.S. Internal Revenue Service had announced that U.S. taxpayers could now begin to claim a "reasonable cause" defense, in the event they were ever to find themselves hit with a penalty in connection with a tax matter for which they had "reasonably and in good faith" relied upon any IRS-published FAQs (frequently-asked-questions) that has to do with new tax legislation.

For Virginia La Torre Jeker, the well-known American tax expert and blogger who is (famously) based in Dubai, the IRS's statement was, well, about as clear as mud...

The Paris-based Association of Accidental Americans (AAA) has said that it has decided to go ahead with its latest complaint against the U.S. State Department, in an effort to force it to make it easier for dual citizens around the world who wish to give up their U.S. citizenships to be able to do so.

The AAA announcement came even as "Loss of Nationality services" in many U.S. embassies and consulates around the world continued to remain closed, due, these embassies and consulates say, to the Covid pandemic, and other factors.

On Wednesday (June 16), viewers of a "virtual" three-hour, full Senate Finance Committee hearing on the subject of President Biden's Fiscal Year 2022 budget were witness to a rare, 6 minute, 42-second exchange between Sen. Elizabeth Warren (D, Massachusetts) and Treasury Secretary Janet Yellen, about Elizabeth Warren's so-called "Ultra-Millionaire Tax."

Americans resident outside of the U.S., particularly those whom the U.S. government considers to be well off, have been wondering how Sen. Elizabeth Warren's recently-unveiled "Ultra-Millionaire Tax Act of 2021" is likely to affect them.

The notoriously cash-strapped Internal Revenue Service is expected to look for help in filling its coffers next year and beyond from Foreign Trust tax forms 3520 and 3520-A – two information-reporting tax forms that are already familiar to U.S. tax experts for their complexity – a well-known tax specialist has said. 

For various reasons, people, including those with U.S. tax obligations,  have long taken advantage of the option to use so-called "nominees" to hold legal title to some of their non-U.S. assets. But while there can be arguably good reasons for doing so, especially in countries where Shariah Law can dictate how assets are distributed when someone dies, it can also result in huge and unexpected problems.

Here, in an excerpt from her most recent blog, Dubai-based tax expert Virginia La Torre Jeker considers some of the issues that can arise.