Receiving U.S. Social Security Abroad: Understand SSA Country List 1

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 →

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 →

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 →

Born Abroad, American by Law: Should You Register Your Child?

Many children born overseas to a U.S. parent are U.S. citizens from birth. This is so even if the parents never registered the birth at a U.S. Consulate or Embassy, or applied for a U.S. passport for the child. Some parents view this as a way to keep the child outside the U.S. tax system, … Continue reading Born Abroad, American by Law: Should You Register Your Child? →

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 →

Substantial Presence: Too Much U.S. Time Means Global Tax—But Exceptions Exist

Many non-Americans underestimate just how easily time spent in the United States can transform them into U.S. taxpayers. Under American tax law, you don’t need a U.S. passport or green card to face very significant IRS tax obligations. Simply spending enough days on U.S. soil may result in being classified as a “resident alien.” That … Continue reading Substantial Presence: Too Much U.S. Time Means Global Tax—But Exceptions Exist →

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 →

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 →

Denaturalized Citizens Forced To Exit, Can’t Escape Exit Tax

In the heart of America’s immigration debate, a lesser-known but seismic issue is emerging. The intersection of denaturalization and the expatriation tax regime is an explosive topic that has not yet been explored. If the expatriation regime applies to a denaturalized citizen, it imposes an exit tax through a deemed sale of worldwide assets as … Continue reading Denaturalized Citizens Forced To Exit, Can’t Escape Exit Tax →