For many Americans, relinquishing U.S. citizenship or green-card status offers an exit from U.S. tax and filing obligations. I have previously written about the harsh tax consequences on Social Security for those who give up U.S. status. Many individuals who are contemplating giving up their U.S. citizenship or relinquishing a green card focus on the possibility of having to … Continue reading Receiving U.S. Social Security Abroad: Understand SSA Country List 1
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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
Global Assets, U.S. Persons: Cross-Border Tax Planning Mandatory
In her recent Forbes article “Foreign Trusts – How Structure Can Prevent a Million-Dollar Penalty,” Priya Royal emphasizes a core maxim of cross-border tax planning: whenever U.S. persons are part of the “clan,” heightened vigilance is required. The same principle holds true when U.S. situs assets are involved in foreign families or their structures. Global … Continue reading Global Assets, U.S. Persons: Cross-Border Tax Planning Mandatory
Exciting Update: Revamped US Tax Primer for Expats & Global Citizens + Must-Watch YouTube Interviews!
Hello subscribers, global go-getters, expats, and anyone navigating the maze of US taxes abroad! I've got some exciting updates that'll make your financial life smoother and your dreams of living overseas a whole lot less taxing. First, I just rolled out a complete refresh of my flagship US Tax Primer for American Expatriates Worldwide and … Continue reading Exciting Update: Revamped US Tax Primer for Expats & Global Citizens + Must-Watch YouTube Interviews!
Residence-Based Taxation: Social Security, Pensions And 30% Withholding
The endorsement of an elective residence-based taxation model by former IRS Commissioner Charles Rettig and former IRS Commissioner Counselor Tom Cullinan, covered in my earlier Forbes article, has sparked important discussions about fairness for Americans abroad. Their piece highlights the burdens of America’s citizenship-based tax system and calls for a shift to treat expats more … Continue reading Residence-Based Taxation: Social Security, Pensions And 30% Withholding
Former IRS Leaders Endorse Residency-Based Tax For Americans Abroad
Nearly a year ago, in the waning days of the 118th Congress, Representative Darin LaHood (R-IL) introduced a groundbreaking piece of legislation that sent ripples through the expatriate community and the international tax world: the Residence-Based Taxation for Americans Abroad Act (H.R. 10468). As I detailed in my earlier Forbes article, this bill represented a bold step … Continue reading Former IRS Leaders Endorse Residency-Based Tax For Americans Abroad
The Sagoo Case: FBAR’s Reckoning In A Globalized World
On September 19, 2025, the U.S. District Court for the Northern District of Texas upended IRS FBAR enforcement in United States v. Sagoo (No. 4:24-cv-01159, N.D. Tex. 2025). Sharnjeet Sagoo, a U.S. taxpayer with international ties, faced over $1 million in penalties for alleged willful failures of the Bank Secrecy Act requirement to report foreign … Continue reading The Sagoo Case: FBAR’s Reckoning In A Globalized World
U.S. Tax Rules: IRAs After Giving Up Citizenship Or Green Card
Imagine over the years that you’ve built a nest egg in a U.S. Individual Retirement Account, Roth IRA, or Simplified Employee Pension IRA. This is a common scenario for many U.S. citizens and green card holders while working in the United States. In a scenario that is becoming increasingly more common, imagine that after years … Continue reading U.S. Tax Rules: IRAs After Giving Up Citizenship Or Green Card
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
5 U.S. Estate Tax Surprises For Nonresident Alien Investors
Foreign investors can win big with United States investments. While holding U.S. assets can be lucrative, the U.S. estate tax regime is complex and often misunderstood by nonresident alien investors. NRAs, those who are neither U.S. citizens nor residents for estate tax purposes, are often very surprised when they learn of the challenges imposed by the … Continue reading 5 U.S. Estate Tax Surprises For Nonresident Alien Investors








