Mel Whitney

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 asse...

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...

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 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 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...

Most US expats who ask whether they are exempt from FATCA reporting are not actually exempt – they are simply below the Form 8938 filing threshold. That distinction matters, because a threshold can be crossed next year while a tr...