What the Blue Wave Means for US Expats
Democratic victories in the House and Senate have set up divided government for President Trump’s final two years in office. For Americans abroad, major tax legislation will become harder to enact…
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Comparing the US/UK CFC Regimes
Owning a foreign company does not necessarily allow its shareholders to defer tax until they receive a dividend. Both the United States and the United Kingdom have controlled foreign company (CFC)…
Read MoreCase Review – IRS Wins Foreign Tax Credit NIIT Case on Appeal
For several years, U.S. taxpayers living abroad have watched an important dispute over whether foreign tax credits can reduce the 3.8% net investment income tax (“NIIT”). Two taxpayer victories in…
Read MoreThe Corporate Transparency Act Just Changed Again: What U.S. Expats Need to Know
On August 14, 2026, a new Financial Crimes Enforcement Network (“FinCEN”) rule became effective that permanently exempts U.S. companies and U.S. persons from the Corporate Transparency Act’s…
Read MoreTaxpayer Advocate Report to Congress Lays Out Compliance Challenges for US Expats
If you’re a U.S. citizen living outside the country, you already know that the American tax system follows you wherever you go. Whether you’re working in London, raising a family in Tokyo, or…
Read MoreIRS Quietly Ends Delinquent FBAR Amnesty – Here's What That Means for Taxpayers
In wholly unexpected news, the IRS has quietly shut down its Delinquent FBAR Submission Procedures (DFSP), just as it quietly ended the Delinquent International Information Return Submission…
Read MoreExiting the US and Abandoning Your Green Card – A Case Study
Leaving the US and abandoning your green card requires navigating a host of challenges from a US tax perspective.
Read MoreComparing the US/UK Applications of the Treaty Saving Clause
Cross‑border taxpayers navigating the U.S.-UK Income Tax Treaty often assume that treaty benefits operate symmetrically. In most areas, they do - but not when it comes to the saving clause, a…
Read MoreMoving to the US? Here’s What You Need to Know
Immigrating to the United States is a major life milestone, but it also brings one of the world’s most complex tax systems into your life. Once you become a U.S. tax resident, you are generally taxed…
Read MoreRenunciation Fee Cut to $450 – What Now for Expats
After years of anticipation, the State Department has finally cut the fee Americans must pay to renounce their U.S. citizenship to $450, down around 80% from its previous fee of $2,350.
Read MoreComparing US/UK Home Sale Gain Exclusions
In this blog, we compare the capital gain exclusions in the United States and the United Kingdom that are available for taxpayers selling a personal residence.
Read MoreComparing US/UK Offshore Tax Amnesty Programs
In this blog, we compare the major tax amnesty programs in the United States and the United Kingdom that are available for taxpayers with unreported overseas assets and income.
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