If you're a U.S. person receiving income from abroad, or a foreign person earning income connected to the U.S., withholding rules can catch you off guard. Getting the basics right now can prevent notices, penalties, and cash-flow surprises later.

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

Own a condo in Manila, a flat in London, or a rental house in Guadalajara? If you're a US citizen, green card holder, or resident alien, the IRS wants to hear about the rent you collect on it — no matter where that property sits or what currency the rent shows up in. Here are the basics of reporting foreign rental income correctly, so a straightforward income stream doesn't turn into a compliance headache.

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.

If your Green Card has expired, or you're starting to think about giving it up for good, there's one myth we need to clear up right away: a plastic card expiring is not the same thing as ending your U.S. tax residency.

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

Tuesday's blog introduced the three covered expatriate tests and the early warning indicators that signal exit tax exposure under IRC Section 877A. If you haven't read that post yet, start there. This Tax Talk Thursday goes deeper — and it focuses specifically on two groups whose situations are more nuanced, more misunderstood, and frankly more dangerous than the general headlines suggest: long-term green card holders and dual citizens. Both groups carry unique risks that sta

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

Now that you have established or become a beneficiary of a foreign trust, you may need to consider whether you have a US income tax return and information reporting requirement. If you are a US citizen, permanent resident, or a US resident taxpayer you may be subject to US taxes and reporting on your worldwide assets.

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.

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.

Foreign financial reporting is no longer just about Swiss bank accounts. Today, U.S. taxpayers may have foreign brokerage accounts, international retirement plans, and cryptocurrency held on offshore exchanges — all of which can trigger complex reporting obligations under FBAR and FATCA. While many taxpayers assume these filings are minor disclosures, recent court cases make clear that the penalties for late or missing FBAR filings can be significant — even when no tax was ow

On December 30, 2025, MKHS Tax Group hosted a live webinar titled “Living in the U.S. Now? Your Tax Obligations as a Nonresident, Inpatriate, or Green Card Holder.” This session was designed for visa holders, green card holders, and their spouses and dependents who are living or working in the United States and are unsure how U.S. tax rules apply to them.