Internal structure in CFCs If you're a U.S. person who owns (or has a stake in) a company incorporated outside the United States, three terms should be on your radar: Controlled Foreign Corporation (CFC), Subpart F income, and GILTI. These rules exist to prevent U.S. shareholders from parking profits offshore indefinitely — and they can generate a current U.S. tax bill even if you never see a dividend from the foreign company. This week, we're breaking down how these three pi

A rental is a rental, right? Not when it's overseas. Foreign rental real estate is stuck on a slower depreciation schedule with no bonus depreciation, and recapture at sale brings in currency translation and FTC sourcing that most software won't catch. Here's the full domestic-vs-foreign comparison.

Foreign Stock Plans and RSUs If you work for a multinational employer and your compensation package includes Restricted Stock Units (RSUs) or participation in a foreign stock plan, you're sitting on more than an investment — you're sitting on a reporting obligation that most people don't discover until it's too late. Whether you're a U.S. person working abroad, a foreign national working in the U.S., or someone who's relocated mid-vesting-schedule, equity compensation adds a

New York City skyline representing shadow payroll and cross-border tax compliance for global employees If you have a client who's working across borders — a US employee on assignment in London, a UK national temporarily in a New York office, or an executive splitting time between two countries — chances are “shadow payroll” has come up in conversation. It sounds like something out of a spy movie, but it's actually one of the most common (and most misunderstood) tools in globa

The green card test — not the card itself — determines U.S. tax residency. This week's Tax Talk Thursday walks through dual-status filing, the LTR 8-of-15-year test, Form 8854 mechanics, and the compliance risks of an expired-but-unterminated green card.

Passive activity loss rules quietly limit how much rental and passive losses you can deduct each year. This week's Tax Tip Tuesday breaks down the income phase-outs, Real Estate Professional Status traps, and documentation gaps that turn a legitimate loss into an audit flag.

The PTE election sounds technical, but the idea is simple: let your business pay a piece of your California tax so you can deduct it federally without a cap. Here's a plain-English breakdown of how it works and who it's for.

The home office deduction is one of the most misunderstood — and most scrutinized — deductions on a tax return. I see it come up constantly in client conversations, and the same question surfaces every time: "Is it really worth claiming? Will it trigger an audit?" The honest answer? Done right, the home office deduction is completely legitimate and worth claiming. Done wrong, it's a red flag that can invite exactly the kind of IRS attention you want to avoid.

Schedule E is one of the most scrutinized sections of your tax return. From rental losses to K-1 mismatches to passive activity rules, the IRS is watching — and documentation is everything.

If you hold a foreign bank account, own international investments, or have financial ties outside the United States, you’ve probably heard the terms FBAR and FATCA — sometimes used as if they mean the same thing. They don’t. Understanding the difference matters, because each has its own form, its own deadline, its own threshold, and its own set of penalties for non-compliance. We know — you've heard about FBAR and FATCA before. But there's a reason we keep coming back to this

Here's the thing most international tax articles won't tell you: by the time you walk into a U.S. embassy to renounce your citizenship or file Form I-407 to abandon your green card, your exit tax exposure is already fixed. There is no going back, no last-minute restructuring, and no do-over. The exit tax under IRC Section 877A doesn't care when you start planning. It cares about what your financial life looked like on the day before you left. That's why identifying the warnin

Did you know that moving to a new state doesn't automatically end your tax obligations to your old one? Learn the six warning signs that your former state may still consider you a resident — and the steps you need to take to protect yourself from a costly audit.

One of the most dangerous misconceptions about the Green Card is that its tax impact is tied to the plastic card's expiration date. In reality, the IRS tracks your status through a "long-term resident" (LTR) clock that begins the moment you are granted permanent residency.

Moving to or from the U.S. mid-year changes your tax residency status, making you a dual-status individual. This means you are both a U.S. tax resident and a nonresident in the same tax year.

US citizens and expats with foreign bank accounts face strict IRS and FinCEN reporting requirements. From FBAR to FATCA, learn the most common mistakes — and how to stay compliant.

If you have a foreign pension or investment account abroad, you've probably never heard of a PFIC. That's a problem — because the IRS has, and the tax rules around them are brutal. What's a PFIC? PFIC stands for Passive Foreign Investment Company. In plain English: almost any foreign fund. Foreign mutual funds, foreign ETFs, foreign pension funds that invest in pooled vehicles — they almost all qualify. If your foreign pension invests in foreign funds (which virtually all d

If you live or work abroad, there's a good chance you have a foreign retirement account — and the U.S. has its own rules for it that don't always match your host country's. From employer contributions being taxed before you retire, to reporting requirements that exist even when you owe zero tax, the gaps between systems catch a lot of expats off guard. Here's what you need to know.

If you own rental property, have a stake in a partnership, or receive income from an estate or trust — Schedule E is where it all lives on your return. It's also one of the most consistently mishandled forms I see. The mistakes aren't always obvious. Wrong depreciation lives, misclassified losses, unreported foreign rental income — they compound quietly, year after year. Let's fix that.

Should you amend a tax return — or wait? In domestic filings, corrections are often straightforward. But when foreign income or international reporting is involved, the decision becomes more strategic. Missed foreign income, FBAR filings, and forms like 8938, 5471, or 3520 can carry penalties even if no tax is owed. This article explains when amending reduces risk, when waiting makes sense, and why international corrections require careful evaluation before taking action.

If you're a freelancer, sole proprietor, or small business owner, filing Schedule C with your tax return is part of your routine. But it’s important to know that some entries on that form can raise questions with the IRS. While most small businesses won’t face an audit, certain red flags can increase your chances of receiving IRS correspondence, a notice, or a closer look at your return.