Mel Whitney
- Non-resident taxation
- Real estate taxation
- Tax optimization
- Bachelor of Science in Business Administration
- Humboldt State University
Articles
Form 5471 Schedule J: Accumulated E&P and PTEP reporting guide for US shareholders
Schedule J of Form 5471 tracks the accumulated earnings and profits – known as E&P – of a controlled foreign corporation, or CFC. Schedule J is sometimes referenced as Form 5471 Sch J in IRS correspondence and practitioner shorthand. It separates previously taxed earnings and profits, referred to as PTEP, from non-previously taxed...
How to change your state of residence before moving abroad: A 2026 guide
To change state residence, focus on 5 core goals: choose a new domicile, establish real ties there, end key ties to the old state, update your records, and complete any required state tax filings. The detailed process below breaks those goals into 7 coordinated actions. A state-residency change before an overseas move is a state-law iss...
Form W-8ECI: Instructions, who must file, and how to use it in 2026
Form W-8ECI is the IRS certificate a foreign person files to certify that their US-source income is effectively connected with a US trade or business – allowing that income to be taxed at regular graduated rates instead of the flat 30% FDAP withholding rate. Under IRC Section 864(c), income qualifies as effectivel...
Foreign withholding tax: A complete guide for US expats in 2026
Foreign withholding tax is a tax deducted at source by a foreign government or a US withholding agent on income paid to nonresident aliens or US persons receiving foreign-source income. It is a mandatory deduction made before income reaches you. US taxpayers can often recover it through the foreign tax credit on Form 1116. Eve...
IRS Form 14653: A complete guide for US expats and offshore filers
What is Form 14653? Form 14653 is the IRS certification form us...
IRS Streamlined Foreign Offshore Procedures (SFOP): a comprehensive guide for expats
The Internal Revenue Service introduced the streamlined foreign offshore procedures to give Americans abroad a structured way to catch up on missed tax filings without facing severe penalties. Inste...