- Corporate taxation
- International taxation
- Nonresident taxation
- Bachelor of Science, Baruch College
- MBA in Taxation, Baruch College
Articles
PFIC explained: What is a PFIC, form 8621 reporting requirements & US tax rules
Passive foreign investment companies (PFICs) are foreign corporations subject to complex US tax rules that can lead to high tax rates, interest charges, and strict reporting obligations. US investors holding shares in foreign funds should understand PFIC tax rules before filing a 2025 return in 2026. A ...
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...
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...