52 guides
The international tax library
U.S. tax law follows your passport, not your address. These guides cover what Americans abroad and Americans with money abroad are required to file, and how to fix it when they did not.
FBAR
7 guides
FinCEN Form 114: who files, how accounts are valued, deadlines, and the penalty rules after Bittner.
6 min read
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.
6 min read
The FBAR Deadline: April 15, the Automatic October Extension, and What Happens After
Congress moved the FBAR deadline to match the tax return and gave everyone an automatic six-month extension. That is the good news. The rest of the story is what happens once October 15 passes.
5 min read
Signature Authority Over a Foreign Account You Do Not Own: Yes, It Can Mean an FBAR
Employees, company officers, and adult children helping a parent overseas often have FBAR obligations for money that is not theirs. The rule turns on control, not ownership.
5 min read
Joint Foreign Accounts and Spouses: When One FBAR Covers Both of You
FinCEN lets one spouse file for both, but only if every account the other spouse must report is jointly owned. One separate account and the shortcut is gone.
5 min read
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.
5 min read
The Willful FBAR Penalty: What "Willful" Means and How the IRS Calculates It
The willful penalty can reach half of an account balance per violation. The IRS's own manual says it bears the burden of proving willfulness. Here is how the fight is framed.
5 min read
The FBAR Statute of Limitations: Six Years to Assess, Two Years to Sue
FBAR penalties live under Title 31, not the tax code. That means different clocks, different forms, and a collection process that does not run through the IRS at all.
FATCA and Form 8938
3 guides
Specified foreign financial assets, the higher thresholds for people living abroad, and what happens when the form is missing.
5 min read
Form 8938 Thresholds: Why Americans Abroad Get Higher Limits, and Who Still Has to File
Form 8938 uses four different thresholds depending on where you live and how you file. Americans abroad get the highest ones, but only if they actually qualify as living abroad.
5 min read
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.
5 min read
Form 8938 Penalties and the Open Statute: What Happens When the Form Is Missing
The dollar penalty gets the attention. The bigger problem is what a missing Form 8938 does to the statute of limitations on your entire return.
Streamlined and disclosure
6 guides
Getting back into compliance: the streamlined procedures, late information returns, and why quiet fixes backfire.
5 min read
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.
5 min read
Streamlined Domestic Offshore Procedures: The 5 Percent Option for U.S. Residents
Moved back to the States? Living here with an account back home? The domestic version of streamlined trades the zero-penalty deal for a single 5 percent penalty. Here is how it works.
5 min read
Writing the Non-Willful Certification: The Most Important Page in a Streamlined Filing
The streamlined penalty relief rests on one signed statement. The IRS asks for the whole story, good and bad. Here is how to think about telling it.
5 min read
Missed FBARs With No Unreported Income: Your Options for Filing Late
Reported every dollar of income but never filed the FBAR? Your situation is different from someone with hidden income, and your strategy should be too.
5 min read
Delinquent International Information Returns: Fixing Missing Forms 5471, 3520, 8938 and More
Reported your income but never filed the foreign corporation, foreign gift or foreign asset forms? The IRS has a procedure for that. It is not an amnesty, and it should be used with care.
5 min read
Why Quiet Disclosures Backfire: Fixing Foreign Account Problems Without Telling the IRS
The tempting move is to start filing correctly this year and hope the past stays quiet. Here is why the rules make that a bad bet, and what to do instead.
Living abroad
9 guides
The foreign earned income exclusion, housing, foreign tax credits, filing deadlines, and Social Security for expats.
6 min read
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.
5 min read
The Bona Fide Residence Test: Proving You Really Live Abroad
The physical presence test counts days. The bona fide residence test asks a harder question: where do you actually live? Here is how the IRS answers it.
5 min read
The Physical Presence Test: Counting 330 Full Days the Way the IRS Does
No intent, no ties, no judgment calls. Just days. But the IRS counts days differently than your calendar does, and one long flight can cost you the exclusion.
5 min read
The Foreign Housing Exclusion and Deduction for 2026: The Formula, the Limits, the High-Cost Cities
Rent in London, Geneva or Hong Kong can eat a salary alive. Section 911 gives qualifying Americans abroad a second break on top of the earned income exclusion. Here is the math.
5 min read
Foreign Tax Credit or Foreign Earned Income Exclusion? How to Choose, and When to Use Both
Both tools prevent double taxation. They work in completely different ways, and choosing the wrong one can cost you for years. Here is how to think it through.
5 min read
Revoking the Foreign Earned Income Exclusion: How It Happens, Sometimes by Accident, and What It Costs
The exclusion is sticky. Once you elect it, it stays until you revoke it, and you can revoke it without meaning to. Getting it back can take years.
5 min read
Filing Deadlines for Americans Abroad: June 15, October 15, December 15, and the Interest Clock
Living abroad buys you more time to file, not more time to pay. Here is how the extensions stack, and how they interact with the FBAR.
5 min read
Self-Employment Tax Abroad and Totalization Agreements: Paying Social Security to Only One Country
The foreign earned income exclusion does nothing for self-employment tax. For freelancers and business owners abroad, the real protection is a totalization agreement and a certificate of coverage.
5 min read
Married to a Nonresident Alien: Filing Status Choices and the Election to Treat Your Spouse as a U.S. Resident
Marrying someone who is not a U.S. person changes your filing options. One election can unlock a joint return, but it also pulls your spouse's worldwide income into the U.S. system.
Foreign entities, trusts and gifts
3 guides
Foreign mutual funds (PFICs), foreign corporations (Form 5471), and foreign gifts and trusts (Form 3520).
5 min read
Foreign Mutual Funds and the PFIC Rules: Why Your Overseas Index Fund Is a U.S. Tax Problem
The sensible, diversified fund your local bank sold you is very likely a passive foreign investment company. The U.S. rules for PFICs are among the harshest in the Code.
5 min read
Form 5471 for Americans Who Own or Run a Foreign Company: Who Files and What It Costs to Miss
Incorporated your consulting business abroad? Sit on the board of a local company? The United States wants an annual report on it, and the penalty for missing one starts at $10,000.
5 min read
Form 3520: Reporting Gifts and Inheritances From Abroad, and Foreign Trust Transactions
A large gift or inheritance from a parent overseas usually is not taxable income. It can still trigger a reporting form with a penalty of up to 25 percent of the gift.
Passports and expatriation
2 guides
Seriously delinquent tax debt and your passport, and the tax side of giving up U.S. citizenship.
5 min read
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.
5 min read
Renouncing U.S. Citizenship: The Exit Tax, Covered Expatriate Tests and Form 8854
Some Americans abroad decide the compliance burden is not worth it. Renouncing ends the future obligation, but the exit itself has tax rules, and the past five years matter.
General IRS guides
22 guides
Collections, settlements, audits and appeals. The same federal rules apply whether you live in Ohio or Osaka.
- Nationwide IRS Representation: Why Your Tax Lawyer's Zip Code Does Not Matter
- U.S. Tax Court: The One Court Where You Can Fight the IRS Before Paying
- A Revenue Officer Was Assigned to Your Case. Here Is What That Means.
- When a Civil Tax Problem Starts Looking Criminal
- The Offer in Compromise: How the IRS Decides What It Will Accept
- IRS Payment Plans: Guaranteed, Streamlined, and the Kind You Negotiate
- Currently Not Collectible: When the IRS Agrees to Leave You Alone
- IRS Penalty Abatement: The Most Winnable Fight in Tax Resolution
- Yes, Bankruptcy Can Discharge Tax Debt. Here Are the Rules.
- The Federal Tax Lien: What It Actually Does to You
- IRS Bank Levy: The 21-Day Window That Decides Everything
- IRS Wage Garnishment: Continuous, Brutal, and Stoppable
- The 10-Year Collection Statute: The IRS Deadline Nobody Tells You About
- Years of Unfiled Returns: How to Come Back Without Making It Worse
- IRS Audit Defense: What Auditors Look For and How Cases Are Won
- IRS Appeals: The Second Opinion Built Into the System
- Small Business IRS Problems: Why They Escalate Faster and What to Do
- Self-Employed and Behind With the IRS: The 1099 Debt Spiral
- The Trust Fund Recovery Penalty: When Payroll Tax Debt Becomes Personal
- Innocent Spouse Relief: When Your Spouse's Tax Debt Should Not Be Yours
- Foreign Accounts and the IRS: FBAR, FATCA, and Coming Clean
- Tax Relief for Military Members and Veterans: Rules Most People Miss
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.