Posts by Ari Propis

Whether by accident or intentionally, many foreign and domestic corporations do not fulfill their filing or registration requirements (i.e. by not paying the annual registration fees or filing annual reports) and have their active/good standing status removed along with many or all of the legal advantages of being a corporation. At this point, the corporation (which might have a status of “forefeited”,...

An important feature of expatriate tax compliance is the need to translate foreign currencies into the U.S. dollar equivalent (which is the basis for all income tax calculations). The IRS provides taxpayers with a few options of how to convert foreign currencies. One option is to use the average foreign exchange rates provided on the IRS website. Interestingly, the IRS does not require taxpayers to use the foreign currency exchange...

The increasing acceptance and utilization of Bitcoin, Ethereum (Ether), and other cryptocurrencies/virtual currencies  to conduct business transactions has made it imperative to be aware of the tax ramifications the accompany their usage. Although the IRS was initially silent on the tax treatment of Bitcoin, it eventually issued a notice of guidance in 2014 (Notice 2014-21) that clarified how it would treat virtual currencies. The...

Tax tip – Fulfillment by Amazon (FBA) and its impact on a non-American’s U.S. tax obligations As the growth of Fulfillment by Amazon (FBA) has exploded in recent years, many non-Americans (i.e. nonresident aliens) around the world have realized that they could also become major retail or even wholesale merchants on Amazon despite the physical distance from their customers living in the U.S. However, along with the opportunity...

Prior to 2017, ownership of a Limited Liability Company (LLC) by a non-American generally did not require the filing of a U.S. tax return with the IRS. Consequently, non-American programmers and other digital nomads that lived and worked outside the U.S. but created an LLC (that was disregarded for tax purposes) to help their operations rarely had any U.S. tax filing obligation.  This was due to the fact that the IRS generally only...