Andrew Coleman
Articles
Tax reform for US owners of foreign corporations: Understanding the Sec 962 election
Owning a company outside the US can feel confusing when you see taxes taken in two places. The Section 962 election is a rule that helps make things fair. It allows an American who owns a foreign-controlled corporation overseas to use the same tax steps that a large US company uses. This means you can lower your bill if the foreign tax rate is no...
Acceptable reasons for renouncing US citizenship: what it means and what happens next
When many Americans face a problem they can’t solve, renunciation sometimes comes to mind. But most people don’t know that giving up US citizenship is a serious and final choice. It must be done in another country, in front of a consular officer. Once it’s done, there is no going back. Renouncing US citizenship can make sense for people...
Demystifying the GILTI high tax exception: expert insights
Many Americans with foreign businesses are surprised when their profits face additional tax from the US, even after paying high local rates abroad. This double taxation often stems from complex global income rules that few understand. The GILTI high tax exception helps limit that extra tax when foreign earnings exceed a certain threshold, offerin...
Form 1120-F: Complete guide for foreign corporations in the US
Filing a corporate tax return in the US takes more than filling out forms – it demands precision and insight. For a foreign corporation doing business across borders, especially in the US, Form 1120-F is the key to showing how income is connected to US activities and how deductions are properly claimed. It transforms complex tax data into a clear...
Understanding Subpart F income: Complete guide for US shareholders
For years, many Americans with overseas companies used foreign entities to delay paying US tax on profits earned abroad. Congress responded by creating Subpart F income rules to close that gap and ensure fairness between domestic and international businesses. When a foreign corporation qualifies as a CFC, its earnings can become taxable in the sa...
RESP: What US expats need to know about education savings and tax implications
Every year, Canadian families pour billions into Registered Education Savings Plans, building a cushion for their children’s future studies. These accounts reward early savers through government grants and years of tax-deferred growth, making the RESP a cornerstone of Canadian education planning. Yet for many US expats in Canada, this same tool c...