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Andrew Coleman
Articles
IRS Constructive ownership rules: A complete guide for US expats (2026)
Constructive Ownership is more than a technical tax term – it is the way the IRS prevents taxpayers, corporations, and foreign companies from sidestepping reporting thresholds. This guide tells you about how these ...
Delinquent International Information Return Submission Procedures (DIIRSP): IRS rules for 2026
As of 2026, the ...
Section 367 foreign transfer tax rules: What US taxpayers must know in 2026
Section 367 can turn an otherwise tax-free corporate exchange into a taxable event when a US person moves property, stock, or intangible assets across the US border. For a transfer completed in 2025, the reporting may in...
Relinquish vs renounce US citizenship: Key differences, tax rules, and what to expect in 2026
Renouncing and relinquishing US citizenship can produce the same nationality result, but they use different legal paths under INA Section 349 and can create different tax timing. For a 2025 expatriation filed in 2026, Fo...
Branch profits tax: How the US taxes foreign corporations on US branch earnings
A foreign corporation’s US operations can face 2 federal tax layers when they produce effectively connected income: the regular 21% corporate income tax under IRC Section 882 and a 30% branch profits tax under IRC S...