International tax compliance

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For U.S. citizens and green card holders abroad

You moved overseas. The Internal Revenue Code came with you.

The United States taxes its citizens on worldwide income no matter where they live. FBARs, Form 8938, the foreign earned income exclusion, foreign funds and foreign gifts all come with their own filing rules and their own penalties. I am Darrin T. Mish, a tax attorney admitted to the U.S. Tax Court, and this site explains those rules in plain English.

$10,000

Aggregate foreign balance that triggers an FBAR, at any time during the year

$132,900

Foreign earned income exclusion for tax years beginning in 2026

June 15

Automatic filing extension for U.S. taxpayers living abroad (interest still runs from April 15)

330 days

Full days abroad within 12 months to meet the physical presence test

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The six questions I hear most

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FBAR

Who Has to File an FBAR? The $10,000 Rule, Explained Without the Jargon

If the combined balance of your foreign accounts topped $10,000 at any moment during the year, you probably have a filing obligation. Here is how the rule actually works.

Streamlined and disclosure

The Streamlined Foreign Offshore Procedures: The Penalty-Free Path for Americans Abroad

For Americans who live abroad and simply did not know, the IRS offers a way back with no penalties at all. The price of admission is a sworn, honest story and complete paperwork.

Living abroad

The Foreign Earned Income Exclusion for 2025 and 2026: How It Works and What It Does Not Cover

Section 911 lets qualifying Americans abroad exclude a large slice of their foreign wages from U.S. income tax. It does not erase your filing obligation, and it does not touch everything.

FATCA and Form 8938

FBAR vs. Form 8938: Two Forms, Two Agencies, Two Sets of Penalties

They ask about many of the same accounts, so people assume one replaces the other. It does not. Here is a side by side comparison built from the IRS's own chart and the governing rules.

FBAR

Bittner v. United States: The Non-Willful FBAR Penalty Is Per Report, Not Per Account

The government tried to fine a dual citizen $2.72 million for paperwork mistakes on five reports. The Supreme Court said no. Here is what the decision changed, and what it did not.

Passports and expatriation

Your U.S. Passport, a Seriously Delinquent Tax Debt, and Living Overseas

For an American living abroad, a passport is not a vacation document. It is how you live, work and come home. A large unpaid tax debt can put it at risk.

Working from overseas

Your time zone is not the problem. Silence is.

IRS international matters run on paper, e-filing and the phone. A signed Form 2848 lets a lawyer deal with the IRS for you, so nobody has to fly home to sort out an FBAR problem or a streamlined submission.

What hurts people abroad is waiting. Penalties for missing information returns can be steep, and the best compliance options are only available before the IRS contacts you first. The fix usually starts with an honest inventory: every account, every return, every year.

I have been licensed since 1993. I am admitted in Florida, Colorado and Texas, and before the U.S. Tax Court and the Supreme Court of the United States. More about me.

Foreign accounts, foreign income, a U.S. passport. Let's talk.

One call sorts out what you are required to file, what is late, and which path back into compliance fits your facts.