Facts: Amy was born in London, England in 1972 to George and Ida, US Citizens who worked
Question:
Facts: Amy was born in London, England in 1972 to George and Ida, US Citizens who worked overseas as US state department employees. George and Ida had lived in Texas for their entire lives prior to 1972. Thereafter, George and Ida resided full time in England. Amy acquired US citizenship at birth under section 301(c) of the Immigration and Nationality Act (INA) and became a British citizen as well. Amy has never visited the United States or any of its possessions. Amy has worked in England her whole life, earning $80,000 per year starting in 1992 as an employee of VW, which grew though annual raises to 295,000 for the calendar year 2021. In 2021, Amy had investments in the British stock market totaling 1 million dollars, Bank Accounts in England, Germany and Switzerland containing 1.5 million dollars, and a passive interest in an advertising firm generating 40,000 in 2021. She had similar income from these activities for the years 209-2020. Amy has filed British income tax returns in every working year and paid British taxes on all her income. Amy has never filed any returns of any sort with the United States government.
Question:
Did Amy have any obligations to file any tax returns of any sort for any year?
If yes, what might the consequences of the failures to file be?
Finally, is there anything Amy could, or should do, to reduce the impact of any failures?
Give your reasoning and valid legal authority for each statement you make, citing the source in each case. Only primary sources are valid, such as the Internal Revenue Code, Regulations and Rulings, and case law. The textbook, annotations in CCH or other texts, or IRS consumer publications, may be useful in focusing your research, but they are not primary authority.
International Marketing And Export Management
ISBN: 9781292016924
8th Edition
Authors: Gerald Albaum , Alexander Josiassen , Edwin Duerr