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 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 →

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 →