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Patrick Hoza - US Tax & Financial Services

USTAXFS Patrick HozaSince 1990, Patrick Hoza has many years of experience with US individual expatriate taxation under his belt, including High Net Worth Individuals, streamline/voluntary disclosure filings and tax consulting, as well as working with large multinationals like Novartis, BP, Hewlett Packard and General Electric. He has extensive knowledge in serving both US expatriates and resident and non-resident aliens with their US tax-related issues. Patrick Hoza is a Tax Director at US Tax & Financial Services, with extensive experience in all aspects of Individual US tax and Expatriation, including Hight Net Worth Individuals and large multinationals.

Patrick started his career in 1990 in California, with Westpro Ltd., as a Senior Tax Consultant, then spent the middle part of his career working at KPMG and Ernst & Young. During his time with Ernst & Young, he worked and lived in Russia, France and finally Switzerland. He has gained a valuable working knowledge of the respective income tax regulations in all of these countries.

Patrick holds a B.A. in International Relations from the University of Colorado, is a member of the National Association of Enrolled Agents and is a Certified Acceptance Agent.

Expatriation

by Patrick Hoza, US Tax & Financial Services

Lefty Gomez 1936Lefty Gomez, an all-star pitcher for the New York Yankees in the 1930's, is credited with saying "I'd rather be lucky than good." He is also credited with earning the nicknames "Goofy Gomez," and "El Goofo." Still, I often think Lefty had it right and today could very well be your lucky day.

If you are a US citizen and want to give up your citizenship but have fretted over unfiled returns or the fact you do not have a US social security number, then the IRS has a procedure for you! It’s called ‘Relief Procedures for Certain Former Citizens’.

This procedure allows an individual that meets the following eligibility requirements to have a “get out of jail free” card.

  1. Your past compliance failures were due to non-wilful conduct.
  2. You have relinquished your U.S. citizenship after March 18, 2010.
  3. You have no filing history as a U.S. citizen or resident.
  4. You did not exceed the threshold in Internal Revenue Code Section 877(a)(2)(A), relating to average annual net income tax for the period of 5 tax years ending before your date of expatriation. This amount is $171,000 for 2020 and is indexed for inflation each year.

1040

by Patrick Hoza, US Tax & Financial Services

While the Streamline Program has been around for quite a few years, it’s worth mentioning again for those US persons that have still not filed their returns or corrected past mistakes but were not aware of the program. The IRS accepts that taxpayers should not be exposed to extremely harsh penalties for a non-wilful failure to comply with all the various tax reporting requirements. The IRS Streamlined Voluntary Disclosure program is specifically for taxpayers who can certify that their failure to file all information, report all income and pay tax was due to ‘non-wilful conduct’ – that is, due to negligence, inadvertence and mistake, or good faith misunderstanding of these legal obligations.

The program is applied differently for US Persons that can qualify under the offshore version of the program, and those that must use the US resident program. We speak to the offshore version below.

Are you eligible?
To be eligible for the Offshore Procedure the taxpayer must meet a non-residency requirement. This requirement is met if:

  • in any one or more of the most recent three years for which the US tax return due date, or properly applied for extended due date, has passed (the ‘covered tax period’)
  • the individual did not have a US abode and was physically outside the United States for at least 330 full days

File the returns, pay the tax
For each of the most recent three years for which the US tax return due date (or properly applied for extended due date) has passed, the procedure requires that the taxpayer:

  • file delinquent or amended tax returns, together with all required information returns
  • file any delinquent FBARs (for each of the most recent 6 years for which the FBAR* due date has passed)
  • pay the full amount of tax and interest due with the delinquent or amended returns