Mel Whitney

Not sure whether to file Form 1040 or 1040-NR? It comes down to your tax residency, and the IRS rules are more nuanced than they appear at first glance. Whether you're filing for the 2025 tax year in early 2026 or planning ahead for 2026, understanding your residency status is essential to choosing the correct form and avoiding costly mistake...

A US entity that directly or indirectly owns more than 50% of one or more other entities required to report under the FBAR rules can submit one consolidated FBAR for the entire group. The report is filed on FinCEN Form 114...

Yes, a non-US citizen can owe US tax for the 2025 tax year if they are a US tax resident or receive certain US-source income. For tax purposes, “foreigner” usually means a non-US citizen, but the real question is whether the person is a resident alien, nonresident alien, or dual-status taxpayer. A resident alien generally re...

Section 1291 is the default PFIC tax regime for a US person who owns a passive foreign investment company and has not made a timely QEF or mark-to-market election. For the 2025 tax year filed in 2026, it can turn certain PFIC gains and distributions into a special tax-and-interest calculation on ...

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...

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...