eBook | Foreign Asset Reporting: Navigating the Choppy Financial Seas.

A Primer on The Foreign Earned Income Exclusion

Ordinarily, the United States taxes U.S. citizens and resident aliens on their worldwide income, even when they live and work abroad for an extended period of time.  To provide some relief, a U.S. citizen or resident who meets certain requirements can elect to exclude from U.S. taxation a limited amount of foreign earned income plus […]

Proven Strategies For Eliminating Excess Credits

There are three proven strategies for eliminating excess credits: 1. Foreign tax reduction planning, 2. Increasing the limitation, and 3. Cross-crediting. Part I of this blog will cover the first two. Part II will cover the third, Cross-crediting. A. Foreign Tax Reduction Planning For U.S. persons in excess limitation positions, foreign tax reduction planning has […]

U.S. Taxation of Entities, Associations, and Partnerships: What’s Your “Situs” Roger?

In the U.S. tax system, there is no characteristic of associations or entities (partnerships, corporations, and trusts) that corresponds exactly to the “nationality” or “residence” of individuals.  For most organizations, however, there is a place – or at least a distinct legal environment – that establishes their existence and identity.  This place, sometimes referred to […]

Understanding the Source of Income Rules – Part I

This blog is a primer on the source of interest rules. It is a four-part series. Let’s begin with some basics. The U.S. taxes U.S. persons on their worldwide income. Why are the source of interest rules important? Because sourcing can have a significant effect on the computation of a U.S. person’s foreign tax credit […]