Mel Whitney
Articles
ECI vs FDAP: Key differences in US tax treatment for nonresident aliens (2026 guide)
The single most important difference between ECI and FDAP is the tax rate and whether deductions are allowed. In a FDAP income vs. ECI comparison, effectively connected income is taxed at graduated rates up to 37% for tax year 2025, with deductions permitted. Fixed, Determinable, Annual, or Periodical (FDAP) income is s...
How to fix FBAR mistakes: amended FBAR instructions, filing late, and Streamlined Procedures
The right correction depends on what went wrong, whether the related tax returns are accurate, whether conduct was non-willful, and whether the IRS has made contact. For 2025 accounts, the FBAR threshold remains more than $10,000 in aggregate foreign accounts, with an automatic extension through October 15, 2026. For common FBAR mistake...
FBAR vs. FATCA for US expats: Key differences, filing rules, and when you need both
FBAR and FATCA are two separate US foreign asset reporting regimes. FBAR is ...
FBAR quiet disclosure: IRS risks, penalties, and safer options
FBAR quiet disclosure is not an official IRS compliance program. It usually ...
How to report foreign assets to IRS: Form 8938 vs 3520 vs 5471 vs 8865
US citizens and green card holders living abroad may need to file up to eight separate IRS and Treasury forms each year to report foreign assets held offshore, including accounts, entities, trusts, and gifts. Foreign ass...
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. ...