Mel Whitney
- Non-resident taxation
- Real estate taxation
- Tax optimization
- Bachelor of Science in Business Administration
- Humboldt State University
Articles
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 ...
Form 8288: FIRPTA withholding tax return - instructions and complete guide
Form 8288 is the US Withholding Tax Return for Certain Dispositions by Foreign Persons. The withholding agent, typically the buyer of a USRPI, withholds 15% of the amount realized (IRC § 1445(a)) and remits the tax with Form 8288 to the IRS within 20 days of the tra...