Ines Zemelman
- Corporate taxation
- International taxation
- Nonresident taxation
- Bachelor of Science, Baruch College
- MBA in Taxation, Baruch College
Articles
US tax treaties: complete guide for expats (2026)
A US tax treaty is a bilateral agreement between the US and a foreign country that reduces or eliminates double taxation on cross-border income. The IRS currently lists 68 treaty entries on Table 3, which was last updated...
What does the "FATCA Filing Requirement" box on Form 1099 mean?
It is a payer or issuer reporting flag, not a box you complete yourself. In current IRS instructions, the 1099 FATCA filing requirement box is tied to chapter 4 account-reporting rules, which are part of FATCA. ...
Form 8858 and Foreign Disregarded Entities: a complete guide
Form 8858 is the IRS return that links your foreign entity's books to your US taxes – and missing it can trigger a $10,000 penalty per entity. Following Farhy, section 6038(b) penalties are treated as assessable in the D.C. Circuit – meaning the IRS can collect them administratively – but the issue remains actively litigated...
Taxation of foreign dividends: How to report US tax, withholding, and foreign tax credits
The taxation of foreign dividends can be complex for US taxpayers, especially expats who invest globally. Tax obligations and withholding requirements vary, but proper reporting helps you avoid double taxation and stay c...
PFIC explained: What is a PFIC, form 8621 reporting requirements & US tax rules
Today, many foreign investment vehicles can be classified as PFICs, including certain foreign mutual funds, index funds, ETFs, and investment structures held through foreign pension arrangements. ...
Assurance Vie for US expats: French tax benefits and US reporting rules
Assurance Vie can work well in France, but US expats need a second tax lens. French income-tax treatment improves after 8 years, FBAR review can start once foreign accounts exceed $10,000 in aggregate, and French withdra...