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

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.