Andrew Coleman

Subpart F income is certain income of a CFC that a US shareholder may have to include in current US taxable income even without a distribution. For the 2025 tax year, the rules still use GILTI terminology; NCTI changes apply to later CFC years. A foreign company can therefore create current US tax before cash reaches its owner. Review T...

Yes. Most US citizens and resident aliens abroad who must file a 2025 federal return can e-file Form 1040 in 2026 when their forms and identification are supported. Most US citizens and resident aliens abroad who must file a 2025 federal return can e-file Form 1040 in 2026 when their forms and identification are supported. Paper filing ...

US citizens married to foreign spouses have three filing options – and choosing the wrong one can mean paying more tax than necessary or pulling a spouse's worldwide income onto a US return unnecessarily. Understanding how to file taxes with a nonresident alien spouse starts with one question: is your spouse a US tax resident?...

The US citizenship renunciation fee cut took effect on April 13, 2026. The State Department reduced the consular fee for a Certificate of Loss of Nationality from $2,350 to $450 – an 80% decrease. That is the entire fee change. The consular appointment now costs what it cost in 2010, before the controver...

A certificate of loss of nationality is the State Department record confirming an approved loss of US nationality. For tax purposes, a 2025 expatriation can also trigger Form 8854, a final dual-status return, and the rules under IRC Section 877A. The physical certificate and the federal tax rules do not always use the same controlling d...

Owning a SARL in France can create US information-reporting obligations and current-income inclusions even when the company pays French tax and distributes no cash. For a US person owning a French business, the first 2026 question is US entity classification: a typical French SARL whose owners all have limited li...