New Self-Employment Tax Risks For U.S. Investors In Global Funds

The U.S. Tax Court decided Soroban Capital Partners LP v. Commissioner (T.C. Memo 2025-52) in May 2025 leaving financial, tax and legal advisors concerned. The court upended assumptions about the self-employment tax exemption for limited partners in hedge funds, and by analogy to venture capital, and private equity partnerships both in the U.S. and abroad. U.S. … Continue reading New Self-Employment Tax Risks For U.S. Investors In Global Funds →

Taxation Of Stock Options For Foreign Nationals Working In The U.S.

Many foreign persons are employed in America and are given stock options as an incentive by the companies for which they work. When a foreign national works in the U.S. and is granted stock options, the taxation of these options can become complex, especially if the individual later leaves the U.S. and becomes a nonresident alien … Continue reading Taxation Of Stock Options For Foreign Nationals Working In The U.S. →

WEBINAR – Back By Popular Demand FBAR, FBAR, FBAR!

Learn all about FBAR and expand services to your clients with confidence. Maybe even land Pope Leo XIV as a new client since his Holiness probably has to file FinCEN Form 114 for the Vatican Bank's accounts. Understand your own compliance risks and what to do if you are not compliant. This is the FBAR … Continue reading WEBINAR – Back By Popular Demand FBAR, FBAR, FBAR! →

Additional Child Tax Credit, Americans Abroad: IRS Is Watching Closely

The Additional Child Tax Credit can provide taxpayers up to $1,700 per qualifying child in 2025 as a refundable credit. The ACTC not only reduces the amount of tax owed but can also result in a refund from the IRS if the credit exceeds the tax liability. Non-refundable credits can only reduce a taxpayer’s tax … Continue reading Additional Child Tax Credit, Americans Abroad: IRS Is Watching Closely →

Foreign Stock Options: 6 Things American Expats Should Know

As more Americans take on international roles, stock options have become a key part of the expatriate executive’s compensation package, especially when working for foreign employers. These options offer exciting opportunities to benefit from a company’s growth, but they also come with complex U.S. tax implications that can catch the unwary off guard. Imagine you’re … Continue reading Foreign Stock Options: 6 Things American Expats Should Know →

PODCAST! Crash Course Info! Renouncing US Citizenship / Relinquishing Green Card – Beware The Exit Tax and More

A very informative podcast - I would say it's a crash course on the US #expatriation regime including the recently issued final IRS regs on the Sec. 2801 transfer tax, lots of tax tips including gifting issues to get below USD 2 million threshold, what NOT TO DO if CBP wants you to sign I-407 … Continue reading PODCAST! Crash Course Info! Renouncing US Citizenship / Relinquishing Green Card – Beware The Exit Tax and More →

FBAR Due Date: Triggers And Key Compliance Rules For U.S. Taxpayers

As the April 15 tax filing deadline approaches, U.S. persons with foreign financial accounts must be aware of their obligation to file the Report of Foreign Bank and Financial Accounts, commonly called the “FBAR”. The filing deadline is April 15, the same due date as one’s U.S. income tax return, but there is an automatic … Continue reading FBAR Due Date: Triggers And Key Compliance Rules For U.S. Taxpayers →

Giving Up Citizenship Or Green Card: Harsh Tax On Social Security

A portion of an individual’s U.S. Social Security retirement, survivors, or disability benefits may be subject to U.S. income tax, regardless if the individual is a U.S. or non-U.S. person. Before delving into the details about tax on Social Security, it is helpful to understand the different nomenclature when it comes to certain benefits. Social … Continue reading Giving Up Citizenship Or Green Card: Harsh Tax On Social Security →

40% Transfer Tax: IRS Final Say On Foreign Gifts, Bequests From “Covered Expatriates”

Seventeen years after Congress enacted IRC Section 2801, the IRS (finally) released final regulations implementing the law on January 10, 2025. It’s been a long wait. The regulations clarify (to a certain extent) the tax implications for U.S. persons receiving certain gifts and bequests from former U.S. citizens and long-term resident green card holders. At its … Continue reading 40% Transfer Tax: IRS Final Say On Foreign Gifts, Bequests From “Covered Expatriates” →

Owning Real Estate Property Overseas: 9 Key U.S. Tax Issues

Purchasing or owning real estate property overseas can be an exciting investment opportunity, but for U.S. persons, it comes with significant tax and reporting obligations. Foreign persons becoming U.S. tax residents (e.g., obtaining a green card) may already own overseas properties and should be aware of the U.S. tax issues they will face at the … Continue reading Owning Real Estate Property Overseas: 9 Key U.S. Tax Issues →