In a case experts say has potentially major repercussions for expatriate Americans, the U.S. District Court for the Eastern District of Texas has ruled that the penalty for so-called "non-willful violations" of the U.S. Foreign Bank Account Reporting regulations should be calculated on a "per-FBAR", rather than per account, basis.

For various reasons, people, including those with U.S. tax obligations,  have long taken advantage of the option to use so-called "nominees" to hold legal title to some of their non-U.S. assets. But while there can be arguably good reasons for doing so, especially in countries where Shariah Law can dictate how assets are distributed when someone dies, it can also result in huge and unexpected problems.

Here, in an excerpt from her most recent blog, Dubai-based tax expert Virginia La Torre Jeker considers some of the issues that can arise.