Andrew Coleman

Quick answer: Bona fide USVI residents who meet the 183-day presence test, maintain no tax home outside the USVI, and satisfy the closer-connection requirement file their income tax return with the Virgin Islands Bureau of Internal Revenue (VIBIR) instead of the IRS, potentially unlocking significant tax advantages. The...

Form 5471 Schedule Q reports a controlled foreign corporation’s income, deductions, taxes, and assets by CFC income group. For a 2025 return filed in 2026, use the published December 2024 Schedule Q with the December 2025 Form 5471 instructi...

Form 5471 Schedule P tracks previously taxed earnings and profits, or PTEP, for certain US shareholders of foreign corporations. For a 2025 tax return filed in 2026, it helps show which CFC earnings were already included in US income. That record becomes relevant when a CFC later distributes cash. Correct PTEP reporting can determine wh...

A cross-border assignment does not switch off US filing rules. For the 2025 tax year, a US person may need Form 1040, Form 2555, Form 1116, FinCEN Form 114, or Form 8938. Global mobility assignee tax filing starts with the named individual, not the employer’s payroll. US citizens and green card holders generally continue reporting...

The best low-tax country depends on your income, local residency rules, and US filing duties. For 2025 income filed in 2026, Americans abroad can still owe US tax even when their new country charges 0% personal income tax. A move that looks attractive on rate alone can change once corporate tax, VAT, state domicile, or foreign-account r...

The portfolio interest exemption is a US tax provision under IRC sections 871(h) and 881(c) that allows qualifying foreign investors to receive interest income from US debt obligations completely free of the standard 30% withholding tax. Without this exemption, every dollar of US-source interest paid to a foreign person...