- Exit tax planning
- International business tax
- Overseas tax obligations
- Tax compliance for expats
- Master's of Accounting, University of Kansas School of Business
Articles
IRS Constructive ownership rules: A complete guide for US expats (2026)
Constructive Ownership is more than a technical tax term – it is the way the IRS prevents taxpayers, corporations, and foreign companies from sidestepping reporting thresholds. This guide tells you about how these rules apply in practice, why they matter, and where they trigger reporting duties. By attributing shares held by famil...
IRS Form 926: filing requirements for US Expats and foreign corporations
IRS Form 926 is the information return that US persons file when transferring property to a foreign corporation. It generally applies to cash, stock, securities, tangible, and intangible property transfers, though several narrow exceptions c...
IRS relief procedures for certain former citizens (2026 guide)
The IRS relief procedures for certain former citizens are still available, for eligible former US citizens who relinquished citizenship after March 18, 2010. Who qu...
Capital gains tax for nonresident aliens: US stocks, property, and FIRPTA
Most nonresident aliens do not pay US capital gains tax on portfolio investments like US stocks, bonds, or mutual funds. The two main exceptions are gains effectively connected with a US trade or business (ECI) and gains realized while you are physically present in the US for 183 days or more in the tax year. US real estate is t...
IRS reasonable cause penalty abatement: How to request relief
Reasonable cause means the IRS may remove or reduce certain penalties if you tried to comply with US tax law but could not because of facts outside your control. For 2025 tax year returns filed in 2026, this often matters when an expat files late, misses Form 8938, receives a Form 3520 or Form 5471 penalty notice, or discovers old FBAR gaps after...
Relief from filing Forms 3520-A and 3520 for certain tax-favored foreign trusts
Under Rev. Proc. 2020-17, the IRS exempts qualifying transactions with, and ownership of, applicable foreign retirement and savings trusts from IRC §6048 reporting. That tax-favored foreign trust reporting relief also removes the §6677 ...