Mel Whitney

A passive foreign investment company is defined by what a foreign corporation earns or holds – specifically, the 75% passive income test or the 50% passive asset test under IRC Sec. 1297(a). A controlled foreign corporation is defined by who owns it – US shareholders owning at least 10% each must collectively hold more than 50% of the...

If you are a US person and your aggregate foreign financial account balances exceeded $10,000 at any point during the calendar year, you must file FinCEN Form 114 – the Repo...

If you're a US citizen or green card holder earning income abroad, one of the first tax decisions each year is whether to use the Foreign Tax Credit (FTC), the Foreign Earned Income Exclusion (FEIE), or both. The choice affects how much US tax you owe, whether you qualify for refundable credits like the Additional Child Tax Credit, and whethe...

Many US taxpayers discover years later that foreign income, bank accounts, or FBARs were never reported — often because they did not realize the rules applied to them. To help eligible ...

An Individual Taxpayer Identification Number is a 9-digit IRS Taxpayer ID for people who need to file or be listed on a US federal tax return but cannot get an SSN. For 2025 returns filed in 2026, ITIN issues often come up for nonresident spouses, foreign depend...

The Foreign Tax Credit (FTC) carryover lets a US taxpayer move qualified foreign income taxes that exceed the Form 1116 limitation back 1 year and forward as many as 10 years. For 2025 returns filed in 2026, balances must be tracked by income category, and section 951A-category taxes cannot be carried over. An unused FTC arises when you...