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Andrew Coleman
Articles
Section 367 foreign transfer tax rules: What US taxpayers must know in 2026
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 in...
Relinquish vs renounce US citizenship: Key differences, tax rules, and what to expect in 2026
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, Fo...
Branch profits tax: How the US taxes foreign corporations on US branch earnings
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 S...
GILTI tax (NCTI): Global Intangible Low Taxed Income definition, calculation, and example
The GILTI tax – Global Intangible Low-Taxed Income – is a US minimum tax on the active earnings of foreign corporations controlled by US shareholders. ...
Where can I cash a United States Treasury check? A complete 2026 guide for Americans at home and abroad
Paper Treasury checks are now uncommon for individual federal tax refunds because the IRS began phasing them out on September 30, 2025. In the 2026 filing season, more than 98% of refunds reported through March 20 were delivered electronically, but paper checks still exist for limited exceptions, older payments and other federal disbursements. ...
Expat payroll explained: How expatriate payroll works and what employers and employees must know in 2026
Moving an employee abroad can put the same compensation into 2 tax and payroll systems. For the 2025 tax year filed in 2026, US employers and expat employees may need to coordinate home-country payroll, host-country withholding, Social Security coverage, Form W-2 reporting, and the employee’s US Form 1040. The result depends on wh...