A recent ruling in 2023 by the U.S. Court of Federal Claims allowed U.S. citizens living in France to offset the net investment income tax using the foreign tax credit for taxes that are paid in France. This outcome is different from a previous court case on this same issue. The IRS has appealed the ruling leaving taxpayers in limbo waiting on the final decision regarding the relationship between the net investment income tax and foreign tax credit.

For taxpayers living and working abroad, it can be quite complicated trying to determine how to file taxes in not one but two tax jurisdictions. The penalties for failing to comply in the U.S. are astronomical. But the clock is ticking on ticking on getting into compliance. Not only does the IRS have additional funding and has recently hired 4,000 more agents but we have a new IRS commissioner. What does that mean for the existing amnesty programs for taxpayers who have either failed to report some of their foreign income or foreign assets? The clock is ticking…

The repeal of Roe vs. Wade is having all sorts of unintended consequences, even in the tax world. In an effort to conform Georgia’s abortion law to tax law, Georgia has changed the definition of a tax dependent to include any humans, including an unborn child. This will result in an additional Georgia tax deduction of $3,000 for each unborn child.