September 18, 2026 - Participants include:
Virginia La Torre Jeker - @VLJeker
John Richardson - @ExpatriationLaw
Today Virginia and John discussed the penalty situation of a U.S. citizen who had always lived in Mexico. He received gifts from his Mexican father and failed to notify the IRS of the gifts. This is a common and very expensive (from a penalty perspective) mistake.
What follows is the ai generated description of the podcast.
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*"John Richardson and tax lawyer Virginia La Torre-Jeker dissect the recent Antonio Cesar Fuentes case involving Form 3520 foreign gift reporting. The IRS assessed a 25% penalty - under IRC 6039F - after Mr. Fuentes failed to report gifts from his non‑U.S. father that exceeded the $100,000 threshold, sparking a $90,000 penalty, refund litigation, and administrative confusion.*
*The conversation explains how filing suit can transfer settlement authority from the IRS to the Department of Justice (26 U.S.C. §7122), create forum issues for U.S. citizens living abroad (they are presumed to live in Washington, DC) , and reveal clashes between IRS and DOJ procedures.*
*The episode highlights the complexity of international gift rules, the severe penalties for noncompliance, and the need for careful reporting."*
