Mel Whitney

FATCA and CRS are two automatic financial account reporting systems that run in parallel. FATCA is a US law that requires foreign banks to report accounts held by US persons to the IRS, while the&n...

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...

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...

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...

For the 2026 filing season, most J-1 nonresident aliens must file a nonresident tax return on Form 1040-NR if they have taxable US-source income. J-1 visa taxes are not optional if you have taxable US-source income. Even with no taxable income, many J-1 holders stil...