The Immigration Consequences Counsel Should Understand When Representing a Noncitizen Who is Criminally Prosecuted for Failing to Disclose Foreign Income or Foreign Bank Accounts

The Immigration Consequences Counsel Should Understand When Representing a Noncitizen Who is Criminally Prosecuted for Failing to Disclose Foreign Income or Foreign Bank Accounts

Tax Law
By Anthony Diosdi The Internal Revenue Service (“IRS”) has been on a hiring spree and is gearing up for a major offensive. There has been a lot of saber rattling coming from the IRS that in the near future there will be a dramatic increase in referrals for criminal prosecution. One area that is always a favorite of the IRS is to go after undisclosed foreign bank accounts and reported foreign income. One group that may be hit particularly by an increase in prosecutions of unreported fotreign income or foreign bank accounts are noncitizens such as green card holders. This article discusses the immigration consequences a nonresident could face if he or she is charged with a tax crime or crimes associated for failing to disclose foreign income and foreign…
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Working Outside the United States? You Can Potentially Exclude $105,900 from Federal Income Taxation

Working Outside the United States? You Can Potentially Exclude $105,900 from Federal Income Taxation

Tax Law
By Anthony Diosdi If you work and earn money outside the United States, Internal Revenue Code Section 911 may permit you to exclude $105,900 of foreign source income from federal income taxation. The purpose of Internal Revenue Code Section 911 is to mitigate the tax and other economic burdens on U.S. persons working abroad by providing for an exclusion from U.S. of up to a specified amount of foreign earned income and housing costs. Internal Revenue Code Section 911(a)(1) permits a U.S. citizen or U.S. residents (with limitations) who has his or her “tax home” in a foreign country and who meets either of two foreign residence-based eligibility requirements to elect to exclude income from federal income taxation. The amount that can be excluded is up to a stipulated amount…
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