Mel Whitney

A US entity that directly or indirectly owns more than 50% of one or more other entities required to report under the FBAR rules can submit one consolidated FBAR for the entire group. The report is filed on FinCEN Form 114...

Yes, a non-US citizen can owe US tax for the 2025 tax year if they are a US tax resident or receive certain US-source income. For tax purposes, “foreigner” usually means a non-US citizen, but the real question is whether the person is a resident alien, nonresident alien, or dual-status taxpayer. A resident alien generally re...

Section 1291 is the default PFIC tax regime for a US person who owns a passive foreign investment company and has not made a timely QEF or mark-to-market election. For the 2025 tax year filed in 2026, it can turn certain PFIC gains and distributions into a special tax-and-interest calculation on ...

Inheriting property in the US doesn't trigger an immediate tax bill – under IRS rules, most inheritances aren't counted as taxable income when you receive them. The...

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...