Andrew Coleman
Articles
Understanding Subpart F income: Complete guide for US shareholders
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...
US citizenship renunciation fee cut 2026: What the State Department change means for you
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...
Certificate of Loss of Nationality: What it is, Form DS-4083, and your 2026 tax obligations
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...
IRS Form 8898: Statement for individuals who begin or end bona fide residence in a US territory
The Form 8898 IRS page covers taxpayers who take the position that they became or ceased to be bona fide residents of 1 of 5 US territories. As of August 2026, the current IRS form and instructions are still the October 2024 revision, which added an online, mobile-friendly submission option. The filing rule turns on both a residency-sta...
Foreign owned single member LLC: 2026 tax and filing requirements guide
A foreign owned single member LLC is one of the most common US business structures used by non-resident investors and entrepreneurs, and also one of the most misunderstood at tax time. A foreign single member LLC is simple to form, but the IRS reporting rules that apply once a foreign person owns it are strict; the penalties for missing them are ...
Form 1120-F instructions for foreign corporations in the US
Form 1120-F is the US income tax return for a foreign corporation with specified US activity or income. For a 2025 calendar-year filer, the main 2026 deadline is April 15 with a US office or June 15 without one. Missing a timely return can cost ECI deductions. File Form 1120-F when a foreign corporation has a US trade or business, certa...