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Articles & tax guides

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Portfolio interest exemption: How foreign investors can earn tax-exempt interest income from US sources

The portfolio interest exemption is a US tax provision under IRC sections 871(h) and 881(c) that allows qualifying foreign investors to receive interest income from US debt obligations completely free of the standard 30% withholding tax. Without this exemption, every dollar of US-source interest paid to a foreign person...

ITIN renewal guide 2026: Expiration rules, status check, and renewal steps

An ITIN expires after 3 consecutive years of non-use on a US federal tax return, or earlier if its middle digits fall in the ranges the IRS phased out between 2016 and 2020. ITIN renewal requires ...

Amending an FBAR: How to correct FBAR mistakes and file an amended return

You can amend an FBAR at any time by filing a corrected ...

Subpart F income vs GILTI: Key differences every US shareholder must know in 2026

Both Subpart F and GILTI force US shareholders of controlled foreign corporations to recognize CFC income currently – even if the CFC has not distributed any cash. Subpart F income vs GILTI is a distinction every CFC owner needs to understand, because the two regimes target different types of income, apply different tax ra...

Exit tax for green card holders: what you need to know

The expatriation tax for green card holders generally matters only after 8 of the last 15 tax years as a lawful permanent resident and at least 1 covered-status test. ...

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