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

If you're holding Bitcoin, Ethereum, or other digital assets on an exchange based outside the U.S. — Binance, a Hong Kong or Singapore-based platform, or an exchange tied to your home country — you may be sitting on a reporting obligation you haven't thought about. Crypto feels borderless, but the IRS and FinCEN don't see it that way. Where your exchange is legally domiciled matters, and getting it wrong can mean penalties that have nothing to do with whether you owed any tax

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 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