The OBBBA – 6 Key Changes to International Tax Rules
The One Big Beautiful Bill Act of 2025 (OBBBA) represents the most significant overhaul of U.S. international tax rules since the Tax Cuts and Jobs Act (TCJA) of 2017.
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Inflation Adjustments for 2026 Tax Items
Recently, the IRS announced the 2026 tax year annual inflation adjustments for a number of tax provisions, including tax rate schedules and other tax changes. Revenue Procedure 2025-32 provides…
Read MoreThree “Gotcha” Rules Affecting Tax Residency
In this blog, we explore three somewhat obscure rules designed to thwart those who try to alternate between tax residencies in order to avoid U.S. taxation.
Read MoreTaxing Social Security Benefits – 4 Approaches in Treaties
For US expat retirees, determining the US income tax rules regarding foreign (non-US) social security benefits is a common concern. While your foreign country of residence may provide an income tax…
Read MoreUnlocking the Benefits of Estate Tax Treaties – 6 Key Aspects
For nonresident aliens (NRAs) who own U.S. property, estate planning can be fraught with complexity and the risk of significant U.S. estate tax exposure. However, estate tax treaties between the…
Read MoreTaking a Treaty Position to Avoid the Exit Tax
In this blog, we discuss how green card holders who are considering abandoning their green cards can utilize the provisions of an income tax treaty to avoid the imposition of the potentially onerous…
Read MoreRescinding an Entity Classification (Check-the-Box) Election
For U.S. expats with a business abroad, tax planning is essential to ensure that your company is operating tax efficiently.
Read MoreStreamlined Amnesty Procedures and Your Stimulus Payment
For many taxpayers, receiving a stimulus payment from the IRS has been a vital financial lifeline during uncertain times. However, for individuals living abroad or with complex international tax…
Read MoreCase Review – Taxpayer Wins Foreign Tax Credit NIIT Case
In a case representing a major win for taxpayers, the U.S. Court of Federal Claims (Claims Court), in Bruyea v. United States, has concluded that the provisions of a U.S. tax treaty can in fact be…
Read MoreIRS to End Automatic Foreign Trust Reporting Penalties
In very welcome news, the IRS Taxpayer Advocate has confirmed on its website that the IRS will end its practice of automatically assessing penalties for late-filed Forms 3520 and 3520-A.
Read MoreInflation Adjustments for 2025 Tax Items
While many tax figures, such as exclusions or penalties, remain the same from year to year, there are certain numbers that are adjusted typically on annual basis, taking into account inflation and…
Read MoreFiling Jointly with Your Non-US Spouse
In certain instances, filing your US federal income tax return jointly with your nonresident alien (NRA) spouse can be advantageous given the lower rates that apply to married couple filing jointly.
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