Tax Warrior Chronicles

Meghan & Harry Moving to Canada? The Tax Implications for the British Royal Couple

Posted on Thu, Feb 13, 2020

By: Rosie Flite


Prince Harry and Meghan Markle have been living in a whirlwind the past year, from welcoming their first child, Archie, to starting their transition from their positions in the royal family. With their plans to stop accepting funding from the UK Sovereign Grant and to move part-time to North America including Canada and the U.S., most likely California, there will be hurdles for them - one of which being taxation. Being royal makes it much more complicated, but we can try to do some analysis under some simplified assumptions.


Even though the family will be splitting their time between the UK and North America, Meghan and Archie must pay U.S. income taxes on their

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International Taxation for Individuals - Part IV: Which Forms Are Commonly Required?

Posted on Thu, Jul 19, 2018

By: Patrick J. McCormick, JD, LLM


Part I of this series focused on income tax obligations for American citizens and residents, with Part II detailing options to mitigate double taxation for those individuals.  Part III covered tax treatment of individuals who are neither citizens nor residents of the U.S., but have income sourced to the country.  In this fourth and final part of this series, we will discuss the forms most often utilized for tax compliance. 


It is important to stress that both income and information reporting requirements exist for foreign interests, with information reporting most often required only for individual U.S. citizens/residents.  Severe penalties exist for

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The Cryptocurrency Conundrum Part III: What We Look To Moving Forward

Posted on Thu, Jun 21, 2018

By: Patrick J. McCormick, JD, LLM


Today, we wrap up our three-part series on cryptocurrency by detailing the related foreign asset information reporting. Part I provided background and macro-level considerations. Part II covered the ambiguities on tax issues due to limited IRS guidance. This final installment, though far from our last post on cryptocurrency issues,  addresses potential answers to open questions and additional prospective issues.


Cryptocurrency Moving Forward

Though the IRS has not issued additional guidance regarding cryptocurrency since 2014, it has focused significantly on cryptocurrency in other ways – specifically, to ensure income associated with cryptocurrency is

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International Tax Attorney Joins D&S

Posted on Mon, Apr 30, 2018

PHILADELPHIA – Drucker & Scaccetti, the region’s premier tax planning and consulting firm, is pleased to announce that Patrick J. McCormick, JD, LLM, has joined its team as a Principal focusing on international taxation and related issues for domestic businesses and individuals.


“I’m happy to be a part of the D&S team and look forward to helping grow its international practice,” says McCormick. “The opportunity to work with such a talented team of CPAs, attorneys and advisors, all dedicated to tax solutions for clients, is exciting.”


Prior to joining D&S, Patrick was an attorney at a New Jersey-based law firm, where he created, developed and led its international practice. He worked on

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IRS Ending Offshore Financial Asset Disclosure Program

Posted on Mon, Mar 19, 2018

By: Dan Marques, CPA, MT


After years of speculation by tax professionals, the IRS announced on March 13, 2018, that the 2014 Offshore Voluntary Disclosure Program (OVDP) will end on September 28, 2018.  What does this mean for you?  If you have undisclosed foreign financial assets and you’re concerned with the potential for criminal prosecution, you will no longer have any available option for leniency after September 28, 2018



The first IRS OVDP was launched in 2009.  The 2009 program allowed taxpayers to come forward and disclose the ownership of foreign assets and report the associated income.  The price to enter the program was a 20% penalty assessed on the highest

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Not So Fast! Tax Filing Season Isn't Over Yet For Those with Foreign Accounts

Posted on Mon, Jun 01, 2015

It is well after April 15th and you’ve timely filed your returns or extended them to later in the year, but you may not be done with your tax filing obligation for the 2014 tax year.  If you have an interest in a foreign financial account, you may be required to file an informational return commonly known as the “FBAR” (Report of Foreign Bank and Financial Accounts) by June 30, 2015.  Unlike income tax returns, the FBAR may not be extended.  Failing to file this form could subject you to a $10,000 penalty! We certainly do not want that to happen to you, so here are a few things to know if you have foreign accounts.


Accounts Subject to Reporting

The definition of a financial account

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Court Rules Online Poker Accounts Must be Included on FBAR, Disregards IRS Instructions

Posted on Tue, Jun 10, 2014

United States v Hom

Online "pocket aces" may be detrimental to your pocket! A district court has found that a taxpayer's accounts at two online poker companies and an online financial company had to be reported on a Foreign Bank and Financial Accounts Report (“FBAR”).  From 2006 to 2007, the taxpayer maintained accounts at PokerStars, PartyPoker, and FirePay that had aggregate values in excess of $10,000 during each year, which he did not report on a timely filed FBAR. The court found that all of these accounts were considered financial accounts located in a foreign country, and were therefore required to be reported.  Accordingly, the Court agreed with the IRS’s imposition of non-willful

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Report of FBAR Due June 30 - No Extensions Allowed

Posted on Thu, Jun 06, 2013


The Tax Warriors at Drucker & Scaccetti remind you that you are required to file Form TD F 90-22.1, Report of Foreign Bank and Financial Accounts (FBAR), if you had a foreign financial account active in 2012. Remember, this report is required even if the accounts did not produce taxable income.

 The FBAR report is an informational form that must be received, for the 2012 reporting year, by the U.S. Treasury Department ("Treasury") on or before June 30, 2013. The fact that this year's the due date falls on a Sunday does not extend the date the form is due to be received by the Treasury. This means you should plan to have your FBAR delivered to the Treasury by Friday, June 28, 2013, to

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2012 Offshore Voluntary Disclosure Initiative

Posted on Mon, Jul 30, 2012

The IRS recently issued two announcements to help U.S. citizens living abroad, including dual citizens, comply with their U.S. filing obligations.  Based on the success of the prior offshore voluntary disclosure initiatives (2009 OVDP and the 2011 OVDI), the IRS, in January, announced a 2012 OVDP.  The IRS news release (IR-2012-64), provides details regarding the 2012 OVDP, including a set of newFrequently Asked Questions (FAQs).


The period covered for the 2012 OVDP is the most recent eight tax years for which the due date has already passed.  Thus, for taxpayers who submit a voluntary disclosure prior to April 15, 2012 (or October 15, 2012, the extended 2011 due date), the disclosure

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New IRS International Filing Requirements: FBAR Still Required

Posted on Fri, Mar 23, 2012

UPDATE:  If you missed the FBAR filing deadline of June 30th, see our post about the IRS Voluntary Disclosure Program!

This week’s examination of new international filing requirements continues with a closer look at IRS Form TD F 90-22, Report of Foreign Bank and Financial Accounts (FBAR). If you missed the first post in this series, scroll down or click here to learn about international income and asset reporting requirements for dual citizens and U.S. taxpayers living abroad.


U.S. citizens with financial interest or signature authority over any foreign financial account (including bank, brokerage, securities, or other types of financial accounts) located outside of the United States,

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