Mel Whitney
- Non-resident taxation
- Real estate taxation
- Tax optimization
- Bachelor of Science in Business Administration
- Humboldt State University
Articles
FBAR quiet disclosure: IRS risks, penalties, and safer options
FBAR quiet disclosure is not an official IRS compliance program. It usually ...
FBAR penalties in 2026: late filing fines, violations, and relief
Most late FBAR cases do not automatically lead to maximum penalties. The biggest risk factor is whether the IRS sees the failure as non-willful or willful. ...
What is FIRPTA? A guide for foreign sellers and US buyers
The Foreign Investment in Real Property Tax Act, FIRPTA, is part of US tax law that can require withholding when a foreign person sells US real estate. In a typical sale, the buyer has the immediate filing duty, not the seller. That is why buyers, closing teams, and foreign owners all need the rules right before funds move at closing.</...
PFIC vs CFC: Key differences, tax rules, and reporting requirements for US expats in 2026
A passive foreign investment company is defined by what a foreign corporation earns or holds – specifically, the 75% passive income test or the 50% passive asset test under IRC Sec. 1297(a). A controlled foreign corporation is defined by who owns it – US shareholders owning at least 10% each must collectively hold more than 50% of the...
How to report Wise and Revolut accounts on FBAR in 2026
If you are a US person and your aggregate foreign financial account balances exceeded $10,000 at any point during the calendar year, you must file FinCEN Form 114 – the Repo...