Uldis Zalcmanis

33 Critically Important Things You Need to Know About Filing US Taxes as an Expat

Let’s talk about filing US taxes as an expat. If you are an expat filing US taxes from abroad this information may help you save some serious money and avoid troubles. Many Americans living abroad are unaware or confused about their U.S. tax filing obligations. The U.S. tax system is unusual, as it taxes based …

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Good News for US taxpayers under and the Portuguese NHR regime – or is it?

  The NHR is quite nuanced and we’ve discussed it in literally dozens of videos here – https://www.youtube.com/c/TaxesforInternationalEntrepreneursandExpats/search?query=nhr We probably have more experience in dealing with private client Portugal / US tax matters than most other firms.   Here’s the latest matter being debated = are capital gains from the sale of US situs movable …

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US Tax Treatment of French social taxes – CSG and CRDS

SUBJECT: LB&I and SBSE Joint Directive on Creditability of French Social Taxes   This Joint Directive provides instructions to Large Business & International and SBSE examiners on the creditability of two French social taxes, the “contribution sociale généralisée” (CSG) and the “contribution pour le remboursement de la dette sociale” (CRDS), for U.S. federal income tax purposes. …

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Return by a Shareholder Making Certain Late Elections To End Treatment as a Passive Foreign Investment Company

Purpose of Form A U.S. person that is a direct or indirect shareholder of a former Passive Foreign Investment Company (PFIC) or a Section 1297(e) PFIC is treated for tax purposes as holding stock in a PFIC and therefore continues to be subject to taxation under section 1291 unless the shareholder makes a purging election …

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Cyrpto Tax for Res Non Doms on the Remittance Basis

We’ve written about crypto in the UK before – https://htj.tax/?s=crypto+uk+ Approximately 2.3 million people in the UK own cryptocurrency.   The default position is that cryptoassets are considered a personal investment, meaning that there is capital gains tax (CGT) when  selling or disposing of cryptocurrency. This default position may change if HMRC suspects tax avoidance.  HMRC doesn’t consider cryptocurrecy to …

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IRS Taxation of Staking Rewards

As a team, we have been focusing on virtual asset taxation from a US perspective  – https://htj.tax/?s=crypto+irs The IRS has not issued any clear guidance on the taxation of staking rewards. In 2014, the IRS issued Notice 2014-21, which provides that cryptocurrency is treated as property for federal tax purposes, but Notice 2014-21 and subsequent Revenue …

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Doing Business in California

Whether or not a CA state return and the $800 payment is due is a function of whether the entity has any nexus with CA.  Particularly whether, as per R&TC § 23101, (b) (1) – (1) The taxpayer is organized or commercially domiciled in this state. https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?sectionNum=23101&lawCode=RTC California defines “doing business” as “actively engaging in …

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