Mel Whitney
- Non-resident taxation
- Real estate taxation
- Tax optimization
- Bachelor of Science in Business Administration
- Humboldt State University
Articles
FATCA and CRS reporting: What US expats need to know
FATCA and CRS are two automatic financial account reporting systems that run in parallel. FATCA is a US law that requires foreign banks to report accounts held by US persons to the IRS, while the&n...
GILTI high tax exception guide: How it works and who qualifies
The GILTI high-tax exception is an annual election that lets you exclude high-taxed CFC income from your GILTI inclusion when the effective foreign tax rate exceeds 18.9% – that's 90% of the 21% US corporate rate, set und...
How to file late FBARs in 2026: Delinquent FBAR submission procedures guidance
Delinquent FBAR Submission Procedures (DFSP) allow US taxpayers to file overdue foreign account reports without maximum penalties. If you missed FBAR deadlines for accounts exceeding $10,000 aggregate, DFSP provides a com...
IRS Form 14654 instructions for SDOP filing: How to certify non-willfulness under the domestic streamlined procedures
Many US taxpayers discover years later that foreign income, bank accounts, or FBARs were never reported — often because they did not realize the rules applied to them. To help eligible ...
What is tax equalization? Guide for US expats working abroad
Tax equalization is an employer policy that keeps a US employee on a foreign assignment paying roughly the same income tax they would have paid at home. The company withholds a “hypothetical tax” from the paycheck and then covers the actual US and host-country tax bills the assignment generates – making tax equalization for US e...
IRS Streamlined Foreign Offshore Procedures (SFOP): a comprehensive guide for expats
The Internal Revenue Service introduced the ...