Meeting a residency test in two countries is one problem. Having both countries actually assess tax on you as a resident, in the same year, is a different and more urgent one. When that happens, you're no longer just planning around the rules — you're in an active dispute, and the clock on how you respond matters as much as the facts themselves.

If you split your time between the U.S. and another country — or moved abroad but kept ties back home — you may meet the legal test for tax residency in both places at once. Dual residency is not automatically a problem, but it is a warning sign that your U.S. filing could be wrong if it is not addressed, and it can lead to the same income being reported as taxable in two countries with no relief unless you claim it correctly.

Every cross-border tax question eventually collapses into the same underlying issue: is this dollar of income U.S.-source or foreign-source? It sounds like a formality, but the answer drives some of the most consequential numbers on an international return — the foreign tax credit limitation under IRC §904, whether a nonresident alien owes U.S. tax at all under §871 or §882, which income falls into which FTC “basket,” and how a tax treaty's sourcing tie-breakers apply.

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

Estimated taxes aren't just an IRS formality — they're one of the simplest tools you have to stay ahead of your tax bill instead of chasing it. Here's why we bring this up every quarter, plus a quick quiz to see where you stand.