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 →

Unregistered U.S. Citizenship: Hidden Risks For American Born Abroad

Each year, thousands of children are born overseas to one U.S. citizen parent and one non-U.S. parent. Under U.S. immigration law, many of these children are U.S. citizens from birth, provided the American parent satisfies a relatively simple test: at least five years of physical presence in the United States, with two of those years … Continue reading Unregistered U.S. Citizenship: Hidden Risks For American Born Abroad →

A Complicated U.S. Tax Life: Foreign Spouses And Community Property

When love crosses borders, tax complexity often follows. I know this from first-hand experience having married a Swiss national almost 4 decades ago. When U.S. citizens marry foreign nationals who are not U.S. tax residents a host of U.S. tax rules can upend marital bliss by causing tax compliance complexities that are often difficult to … Continue reading A Complicated U.S. Tax Life: Foreign Spouses And Community Property →

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 →

Corporate ‘Loans’: The Debt v. Equity IRS Challenge And Tax Nightmares

Lenders who advance cash to corporations often do so with a clear expectation: the company will repay the principal and will pay interest, and the borrower will report interest income. Yet for U.S. taxpayers the moment of truth comes much later, sometimes years after the money has left the bank—when the IRS, or a court, … Continue reading Corporate ‘Loans’: The Debt v. Equity IRS Challenge And Tax Nightmares →

A Tale Of Two Retirees: New Senior Tax Deduction And Foreigners’ Social Security

While a campaign promise by President Donald Trump to eliminate income taxes on Social Security benefit income was not fulfilled, seniors were granted certain relief. The landmark tax legislation, the One Big Beautiful Bill Act (H.R. 1), signed into law on July 4, 2025 introduced a temporary special deduction for taxpayers aged 65 or older. The Social Security Administration … Continue reading A Tale Of Two Retirees: New Senior Tax Deduction And Foreigners’ Social Security →

WEBINAR – Remote Work, Global Teams & U.S. Tax: What Every CPA and EA Needs to Know

Some exciting news. I am presenting a webinar on Monday, July 28 2025. 2 IRS CPE credits. 12:00 PM ET | 11:00 AM CT | 09:00 AM PT 90 MINUTES Hope to see you there. Please share with your colleagues and friends who may have interest in this topic. REGISTER AT THE LINK: https://educatorprime.com/product/remote-work-global-teams-u-s-tax-what-every-cpa-and-ea-needs-to-know WEBINAR … Continue reading WEBINAR – Remote Work, Global Teams & U.S. Tax: What Every CPA and EA Needs to Know →

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 →

“Revenge Tax” is Scrapped From The One Big Beautiful Bill

BREAKING NEWS --- On June 26, 2025, Treasury Secretary Scott Bessent announced a "deal" between the US and the G7 nations (Canada, France, Germany, Italy, Japan, and the UK) to exempt US companies from certain foreign taxes, prompting him to request Congress to drop proposed new Internal Revenue Code Section 899 from the One Big … Continue reading “Revenge Tax” is Scrapped From The One Big Beautiful Bill →

Tax Challenges: Foreign Owned U.S. Real Estate Via Single-Member LLC

For some time, foreigners have been drawn to the U.S. real estate market due to its stability, potential for appreciation, and the reliable legal framework in America. A frequently used investment vehicle is a single-member limited liability company created under the laws of a U.S. state. A SMLLC offers liability protection and flexibility. The U.S. … Continue reading Tax Challenges: Foreign Owned U.S. Real Estate Via Single-Member LLC →