Marrying A Non-U.S. Citizen? Your S Corp May Be At Risk

U.S. citizens entering marriages with nonresident aliens face a range of tax complexities that extend well beyond routine compliance. In my earlier Forbes article, “A Complicated U.S. Tax Life: Foreign Spouses and Community Property”, I examined how foreign community property regimes, which are prevalent in civil law jurisdictions (e.g., many countries in continental Europe, as … Continue reading Marrying A Non-U.S. Citizen? Your S Corp May Be At Risk →

Home Sale, Forced To Sell Abroad? U.S. Tax Rules In Uncertain Times

Heightened geopolitical tensions across parts of the Middle East are prompting some expatriates to reconsider their long-term plans. For some, this may mean a rapid relocation. Hand in hand with that decision often comes another: whether to sell a residence. As broader economic uncertainty continues to unfold, including market instability, these decisions are increasingly being … Continue reading Home Sale, Forced To Sell Abroad? U.S. Tax Rules In Uncertain Times →

Renounce U.S. Citizenship Fee Cut To $450—But Tax Traps Remain

The U.S. Department of State just cut the citizenship renunciation fee from $2,350 to $450, but exit tax rules, Social Security limits, and transfer tax traps still create major consequences. For Americans contemplating expatriation, the change may seem like a major victory. For years, critics argued that the United States imposed the highest administrative fee … Continue reading Renounce U.S. Citizenship Fee Cut To $450—But Tax Traps Remain →

Own A Foreign Corporation? New Case Lets IRS Collect $10K Immediately

A new court case now allows the IRS to immediately collect $10,000 penalties from U.S. owners of foreign corporations who fail to file Form 5471. For taxpayers with foreign corporations, the IRS just strengthened its hand in collecting reporting penalties without going to court. The so-called “Farhy defense” suffered another major blow on February 27, … Continue reading Own A Foreign Corporation? New Case Lets IRS Collect $10K Immediately →

Kwong Case: IRS May Owe You Money, Cut Penalties

Taxpayers have often struggled with shifting tax filing deadlines and complex IRS penalty calculations. But if some of those filing deadlines were legally postponed by an act of Congress, certain penalties and refund interest may have been incorrectly calculated by the IRS, entitling impacted taxpayers to relief. A recent federal court case may offer some … Continue reading Kwong Case: IRS May Owe You Money, Cut Penalties →

IRS Under Bisignano: Is More Aggressive Offshore Enforcement Coming?

Right before the U.S. tax filing season officially opened on January 26, the Internal Revenue Service announced significant leadership changes that have drawn cautious scrutiny from tax professionals. Practitioners with the high-net-worth clients and those who assist Americans living abroad are paying close attention. While IRS leadership transitions regularly occur, the timing and substance of … Continue reading IRS Under Bisignano: Is More Aggressive Offshore Enforcement Coming? →

Some Foreigners Can’t Receive U.S. Social Security Abroad: Understanding SSA Country List 2

Most people assume that once they have qualified for Social Security based on their U.S. earnings, their monthly benefit will follow them anywhere in the world for life. This is true for U.S. citizens. But for non-U.S. citizens, including former U.S. citizens and former green-card holders, the rules are very different. These individuals are classified … Continue reading Some Foreigners Can’t Receive U.S. Social Security Abroad: Understanding SSA Country List 2 →

IRS Drops Form 708: 40% Tax, Gifts & Bequests, “Covered Expatriates”

The Internal Revenue Service has released the final version of Form 708, titled “United States Return of Tax for Gifts and Bequests Received from Covered Expatriates,” (revision dated December 2025) along with detailed draft instructions (revision dated December 2025). As of today’s publication, the accompanying instructions remain in draft form available only as a draft … Continue reading IRS Drops Form 708: 40% Tax, Gifts & Bequests, “Covered Expatriates” →

Exclusive Citizenship Act: Unintended Consequences Continue To Emerge

I have previously written how changes to U.S. citizenship and expatriation rules often produce consequences far beyond what legislators appear to anticipate. Whether in the tax arena or in the administration of federal benefits, citizenship status functions as a foundational legal concept, not a standalone policy. Senator Moreno’s proposed “Exclusive Citizenship Act” underscores this point. … Continue reading Exclusive Citizenship Act: Unintended Consequences Continue To Emerge →

Moreno’s Fast-Track Citizenship Bill: Tax & Social Security Bombs, Diplomatic Chaos & More

One email from a tribal member sparked today’s article. A Native American reader of my recent Forbes piece on Senator Bernie Moreno’s Exclusive Citizenship Act of 2025 wrote in with a simple, powerful question: “How would this affect us?” In fewer than 10 words, that message prompted me to dig much deeper. What follows is … Continue reading Moreno’s Fast-Track Citizenship Bill: Tax & Social Security Bombs, Diplomatic Chaos & More →