Marie Sapirie is a contributing editor for Tax Notes, a nonprofit tax publisher, where she writes about federal taxation. Prior to joining Tax Notes, she practiced tax law at Covington & Burling and served as a law clerk for Judge D. Brooks Smith of the United States Court of Appeals for the Third Circuit and Judge Glen E. Conrad of the United States District Court for the Western District of Virginia. Marie received her JD from William & Mary Law School and her undergraduate degree from Georgetown University. Prior to law school she taught at a middle school in Japan.

Charles Bruce is Chairman of American Citizens Abroad Global Foundation and Legal Counsel of ACA. He is an American tax lawyer and practiced in Washington, DC, London and Lausanne. He currently divides his time between Washington and London. At various times he served on the tax staff of the US Senate Finance Committee and taught tax law at Institut für Ausländisches und Internationales Finanz- und Steuerwesen, Hamburg University, Hamburg, and in the Graduate Law Program, Georgetown University Law Center, Washington, DC.

"How the Senate’s Rules and Precedents Shape the Tax Law" by Marie Sapirie

Concurrent Resolution

Donate to ACAGF's Educational and Research Work in Support of Residence-Based Taxation

Glen Frost, Assistant ACA Legal Counsel and Marylouise Serrato, ACA Executive Director give an update on the changes in the Child Tax Credit (CTC) included in the recently passed legislation, American Rescue Plan.

Child Tax Credit

We chat with Marylouise Serrato, Executive Director of American Citizens Abroad, about how the CARES Act stimulus and economic support has been working for Americans living and working overseas and how the problems American expats have encountered with the support can help with getting Residency-based Taxation legislation passed.

American Citizens Abroad Memorandum to Congress, Treasury and IRS: Payment of 2020 Recovery Rebates to Individuals Abroad

State Department Federal Credit Union and ACA Ready to Help Americans Overseas Receive Rebate Recovery Payments

Tax Fairness for Americans Abroad: An Idea Worth Fighting For!

Learn More about the Tax Fairness for Americans Abroad: An Idea Worth Fighting For Campaign

International Postal Service Disruptions

IRS Economic Impact Payment Information

IRS Phone numbers:

1-800-829-1040

US-based number (267) 941-1000

Part 2 of our interview with Caroline Ciraolo, partner with Kostelanetz & Fink and former Acting Assistant Attorney General of the US Department of Justice's Tax Division, we take a deeper dive into the types of tax professionals and government officials that may play a role in a client’s tax matters, the nature and risks of an “eggshell” audit, the scope of applicable privileges, best practices for vetting clients and managing an examination or investigation, and much more.  

Caroline’s practice focuses on civil tax controversies, including representation in sensitive audits, administrative appeals, and litigation, providing tax advice, conducting internal investigations, and representing individuals and entities in criminal tax investigations and prosecutions. During her tenure with the Justice Department, Caroline was actively involved in all aspects of Tax Division operations and responsible for approximately 500 employees, including more than 360 attorneys in 14 civil, criminal and appellate sections.  Under her leadership, the Division reached agreements with 80 Swiss financial institutions that admitted to facilitating tax evasion and the avoidance of reporting requirements by U.S. accoun tholders, increased civil and criminal enforcement with respect to offshore tax evasion, employment tax violations, and traditional tax offenses, assisted the IRS through summons enforcement proceedings, and engaged in affirmative and defensive litigation involving abusive tax shelters and schemes, refund claims, and challenges to statues and regulations.

Caroline is Vice President of the American College of Tax Counsel, Chair of the Civil and Criminal Tax Penalties Committee of the American Bar Association’s Section of Taxation, and an Adjunct Professor at the Georgetown University Law Center (International Tax Controversies, Tax Fraud and Tax Crimes) and University of Baltimore School of Law Graduate Tax Program (Investigation, Prosecution and Defense of Tax Crimes).

Click here to read Caroline’s full bio

Charles Bruce is Legal Counsel of ACA, Chairman of ACA’s sister organization, ACA Global Foundation, former Tax Counsel of the Senate Finance Committee, Adjunct Professor of Law at Georgetown University Law Center, in Washington, and Visiting Professor, Institute of Foreign and International Finance and Taxation, Hamburg University. He divides his time between London and Washington DC.

Listen to Part 1 of our interview or here

We speak with Caroline Ciraolo, partner with Kostelanetz & Fink and former Acting Assistant Attorney General of the US Department of Justice’s Tax Division, and Charles Bruce, Legal Counsel of American Citizens Abroad and Chairman of American Citizens Abroad Global Foundation about non-filers and the CARES Act stimulus payments, voluntary disclosure, streamlined filing compliance procedures, delinquent international information return submission procedures, and more!

Caroline’s practice focuses on civil tax controversies, including representation in sensitive audits, administrative appeals, and litigation, providing tax advice, conducting internal investigations, and representing individuals and entities in criminal tax investigations and prosecutions. During her tenure with the Justice Department, Caroline was actively involved in all aspects of Tax Division operations and responsible for approximately 500 employees, including more than 360 attorneys in 14 civil, criminal and appellate sections.  Under her leadership, the Division reached agreements with 80 Swiss financial institutions that admitted to facilitating tax evasion and the avoidance of reporting requirements by U.S. accountholders, increased civil and criminal enforcement with respect to offshore tax evasion, employment tax violations, and traditional tax offenses, assisted the IRS through summons enforcement proceedings, and engaged in affirmative and defensive litigation involving abusive tax shelters and schemes, refund claims, and challenges to statues and regulations. 

Caroline is Vice President of the American College of Tax Counsel, Chair of the Civil and Criminal Tax Penalties Committee of the American Bar Association’s Section of Taxation, and an Adjunct Professor at the Georgetown University Law Center (International Tax Controversies, Tax Fraud and Tax Crimes) and University of Baltimore School of Law Graduate Tax Program (Investigation, Prosecution and Defense of Tax Crimes).

Click here to read Caroline’s full bio

Charles Bruce is Legal Counsel of ACA, Chairman of ACA’s sister organization, ACA Global Foundation, former Tax Counsel of the Senate Finance Committee, Adjunct Professor of Law at Georgetown University Law Center, in Washington, and Visiting Professor, Institute of Foreign and International Finance and Taxation, Hamburg University. He divides his time between London and Washington DC.

IRS May 11 2018 Webinar

Court Grants IRS Summons of Coinbase Records

Brian Booker, Former CPA, Indicted for Failing to Report Foreign Bank Accounts and Filing False Documents with the IRS

US Professor Hit with US$100M FBAR Penalty for Hiding US$200M in Assets

United States of America, Appellee, v. Louis Kovel, Defendant-appellant, 296 F.2d 918 (2d Cir. 1961)

We speak with David McKeegan, Daria Prohorenko and Charles Bruce about some of the things that expat taxpayers need to focus on with respect to the recent CARES Act and other legislation and guidance that is tumbling out of Treasury Department and IRS now. David and Charles also discuss what is happening with the community of tax return preparers, especially in light of the COVID-19 pandemic.

Daria Prohorenko, is a Certified Public Accountant that has partnered with Greenback Expat Tax Services for over 7 years and resides in Panama.

IRS Coronavirus Platform 

IRS Form 14653

American Citizens Abroad Expat Tax Services Directory

American Citizens Abroad / SDFCU Account

Coronavirus Pandemic Tax Changes Expats Should Know

[Video] Coronavirus Tax Deadlines & Changes for Expats

We speak with Katelynn Minott, CPA with Bright!Tax, Allyson Lindsey, with Bright!Tax, and Charles Bruce, Legal Counsel of ACA and Chairman of ACA Global Foundation about some of the things that expat taxpayers need to pay attention to this tax season, in particular, things falling out from the recent CARES Act, along with what Bright!Tax sees happening with the expat tax preparer community in the coming months.

The CARES Act was signed into law on March 27. It's 883 pages in length. It started off in January 2019 as modest a bill to repeal the excise tax on high-cost employer-sponsored health coverage; as such, it passed the House in July 2019. After languishing, in the Senate, became the vehicle for the $2 trillion coronavirus relief act, with changes made in the Senate on March 20, 2020 and many more thereafter. It passed the Senate on a 96-0 voice vote on March 25. After intense negotiations, it passed the House essentially on a voice vote on March 27.

Bright!Tax is a leading global expat tax preparation firm, with clients in almost every country in the world.

Katelynn Minott is partner and managing CPA at Bright!Tax. She has worked in the field of expat tax preparation for 10 years, having joined Bright!Tax from PwC. Katelynn is an expat herself, and a recognized expert in US expat tax matters; her Twitter account (@BrightTax) is on of Forbes Top Tax Twitter Accounts to Follow in 2020, and she is regularly called on by national media outlets like CNBC to provide comments on new expat tax developments.

Allyson Lindsey is a Partner and Lead CPA at Bright!Tax. She joined the firm from Deloitte, where she worked as a Tax Senior advising international clients across a range of compliance issues.

Bright!Tax’s Stimulus Rebate Summary Page for Expats

IRS Coronavirus Platform

American Citizens Abroad Expat Tax Services Directory

ACA/SDFCU Account

In our premier episode of the ACA Tax Cast, we chat with Glen Frost, Managing Partner of Frost & Associates and Marylouise Serrato, Executive Director of ACA about the COVID-19 stimulus package.

The AICPA chart for the State tax deadlines

The summarized, new SBA loans, referenced as part of the CARES act

American Citizens Abroad

American Citizen’s Abroad Letter to Congress, Treasury and IRS

State Department Federal Credit Union and ACA Ready to Help Americans Overseas Receive Rebate Recovery Payments

American Citizens Abroad Memorandum to Congress, Treasury and IRS: Payment of 2020 Recovery Rebates to Individuals Abroad

Introducing the newest podcast from ACA, the American Citizens Abroad Tax Cast, premiering on March 31st. Throughout the series, we'll cover tax law changes, shifting deadlines, beefed-up enforcement, and more, with the professionals who can help us all get a better grasp of it all. Tune in on March 31st wherever you get your podcasts, when we'll discuss the fallout happening from COVID-19, including the recovery rebates, changing deadlines, and more with Glen Frost, from Frost Tax Law, and Marylouise Serrato, Executive Director of ACA.