Andrew Coleman

For the 2026 filing year, based on 2025 income, partnerships with foreign partners must act as withholding agents on effectively connected taxable income, or ECTI, under section 1446. That filing job now sits alongside the separate 10% transfer-withholding rules under section 1446(f), which apply when a foreign partner sells a partnership interes...

For US expats, a health savings account can be one of the most valuable financial tools you carry abroad, but the IRS HSA rules around contributing, spending, and reporting change the moment you leave the US. US expats can generally use existing health savings account (HSA) funds abroad for qualified medical expenses, but many cannot ke...

A Europe golden visa usually means residence by investment under one country’s law, not citizenship, and not a single EU-wide permit. In 2026, the main routes still worth comparing are: Portugal&rsqu...

Form 2350 is a special IRS filing extension for US citizens and resident aliens abroad who expect to claim the Foreign Earned Income Exclusion or the foreign housing exclusion or deduction on Form 2555, but do not yet meet the residency test by the normal filing deadline...

The IRS imposes a $10,000 initial penalty for not filing Form 5471 per tax year – regardless of whether any tax is owed (IRC §6038(b)). The penalty multiplies per foreign corporation: a taxpayer with three foreign corporations who misses one year faces $30,000 in initial penalties alone. In addition, a missed Form 5...

At a glance Who must file: US citizens who relinquish citizenship, long-term residents who end US tax residency, and certain individuals with ongoing reporting obligations for deferred tax, eligible d...