International tax compliance

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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.

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).

Passports and expatriation

2 guides

Seriously delinquent tax debt and your passport, and the tax side of giving up U.S. citizenship.

General IRS guides

22 guides

Collections, settlements, audits and appeals. The same federal rules apply whether you live in Ohio or Osaka.

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.