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.
Read MoreForeign Companies
U.S. tax and reporting for foreign companies and investments, including Form 5471, GILTI, PFICs and entity classification.
Rescinding 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 MoreSupreme Court Rules on Constitutionality of Transition Tax
In this week’s blog, we discuss a recent Supreme Court decision upholding the constitutionality of the Section 965 transition tax, which was imposed at the end of 2017. We also discuss the impact the…
Read MoreCircuit Court Reverses Taxpayer-Friendly Decision on Form 5471 Penalties
In a surprising decision last year, the U.S. Tax Court, in Farhy v. Commissioner, 160 T.C, No. 6 (April 3, 2023), held that the IRS lacks the statutory authority to assess certain Form 5471…
Read MoreCorporate Restructuring – A Trap for the Unwary Expat
For US expats with businesses abroad, it’s important to understand the US tax implications of your business structuring and operations.
Read MoreThe Onerous Taxation of PFIC Distributions
In previous blogs, we’ve discussed some of the basics of PFIC ownership, including PFIC reporting, PFIC elections, and whether gifts are subject to the PFIC rules.
Read MoreThe Ins and Outs of Gifting PFICS
To get this blog started, let’s take the following situation (which is not so uncommon): A U.S. citizen living abroad holds a portfolio of foreign mutual fund investments and decides that he’d like…
Read MoreTax Court Rules Against IRS on Form 5471 Penalties
On April 3, 2023, the U.S. Tax Court, in Farhy v. Commissioner, 160 T.C, No. 6 (April 3, 2023), made a surprising but welcome decision on international form penalties. The Court held that the IRS…
Read MoreIRS Form 8832 and Foreign Trusts
For U.S. business owners living abroad, one of the key U.S. basic concepts to understand is that your foreign entity may be classified differently under the U.S tax law than its legal classification…
Read MoreThe QEF Election for PFICs
When investing in a business overseas, expats should be wary of the passive foreign investment company (“PFIC”) rules, which trigger heightened reporting requirements and can have onerous tax…
Read MoreThe PFIC Tests and Review of New Regulations
When a U.S. expat invests in a business overseas, one of the key questions that should be addressed is whether the company structure is subject to the U.S anti-deferral regimes. One such regime is…
Read MoreReasonable Reliance Defense Against 5471 Penalties
For U.S. expats owning a foreign corporation, reporting on the Form 5471 can be particularly challenging.
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