Ines Zemelman
- Corporate taxation
- International taxation
- Nonresident taxation
- Bachelor of Science, Baruch College
- MBA in Taxation, Baruch College
Articles
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...
Dual citizenship taxes: Complete guide for US expats (2026)
US dual citizens must file a federal tax return with the IRS each year if their gross worldwide income meets the filing threshold for their filing status and age, or if another filing trigger applies, regardless of their country...
Resident citizens vs non-resident citizens vs residents for tax purposes: US tax residency status explained
Citizenship and tax residency are not the same thing – and for many people, that gap comes as a surprise. A US citizen living abroad is still generally inside the US tax system, while a ...