Andrew Coleman

Renouncing and relinquishing US citizenship can produce the same nationality result, but they use different legal paths under INA Section 349 and can create different tax timing. For a 2025 expatriation filed in 2026, Form 8854, the $206,000 liability test, and the $890,000 gain exclusion are key federal tax figures. If the expatriation...

An EIN for foreign entity use is a 9-digit identifier the IRS assigns to businesses and other organizations. It is also called a federal tax identification number, but it is not the same as an individual taxpayer identification number or a foreign-country TIN. For the 2025 tax year filed in 2026, the key question is not whether the owne...

A foreign corporation’s US operations can face 2 federal tax layers when they produce effectively connected income: the regular 21% corporate income tax under IRC Section 882 and a 30% branch profits tax under IRC Section 884. A treaty may reduce the second layer to 5% or, under narrow conditions, 0%. This guide explains the 2025 ...

Form 3520 is an IRS information return used by US persons and certain estate executors to report specified foreign trust transactions, foreign trust ownership, and large gifts or bequests from foreign persons. For 2025 activity, filing errors ca...

US citizens abroad can invest through US or foreign brokerage accounts, but the tax reporting rules do not stop at the US border. For the 2025 calendar year, a US person's foreign financial accounts, including foreign brokerage accounts, can trigger FBAR if their aggregate value exceeds $10,000 at any time. Form 8938 can also apply ...

Section 367 can turn an otherwise tax-free corporate exchange into a taxable event when a US person moves property, stock, or intangible assets across the US border. For a transfer completed in 2025, the reporting may include Form 926, a gain recognition agreement, Form 5471, or a Section 367(b) notice filed with the 2025 return in 2026. <...