Mel Whitney

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 ...

Inheriting property in the US doesn't trigger an immediate tax bill – under IRS rules, most inheritances aren't counted as taxable income when you receive them. The...

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...

Foreign rental property depreciation requires the use of ADS – the Alternative Depreciation System, which is one of the two systems within MACRS. Here is what that means in practice: Foreign residential rental property used predominantly outside the US must be depreciated under ADS. ADS uses straight-line deprec...