Mel Whitney

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...

Form W-8BEN-E is the IRS certificate used by foreign entities to establish their status as beneficial owners of US-source income and to claim reduced withholding rates under a tax treaty or FATCA exemption. The IRS W-...

The single most important difference between ECI and FDAP is the tax rate and whether deductions are allowed. In a FDAP income vs. ECI comparison, effectively connected income is taxed at graduated rates up to 37% for tax year 2025, with deductions permitted. Fixed, Determinable, Annual, or Periodical (FDAP) income is s...

US citizens and resident aliens abroad must report foreign self-employment income on a US tax return when they meet the filing rules for the 2025 tax year. The key issue is that self-employment tax on foreign earned income is separate from income tax, even when the Foreign Earned Income Exclusion (FEIE) reduces taxable income on Form 1040. ...