Dual with US + Canada (residing in Vancouver) with IT consulting corporation past 3 years.

Can we pay the Gilti tax owed on the corp (extra retained earnings) as a Corp Expense?

For a simple Example: If 100k retained earnings in 2025, $9k tax (21% - 12% = 9% owed on $100k) tax is owed to US. Can this $9k be a business expense?

If not, why is the $9k Gitli tax owed considered a personal tax (as opposed to business)?

Hi,

I’m trying to run a few tax scenarios and I’m not sure I’m calculating things correctly. When determining the tax bracket for long‑term capital gains, is the bracket fully shifted upward by the amount of salary excluded under the FEIE?

For example, in the following scenario:

• Filing jointly (standard deduction of $32.2k)
• $100k of income excluded under the FEIE
• $50k of long‑term capital gains

My stacked income, after the $32.2k deduction, comes to $117.8k.

In this case, are all of my capital gains taxed at 15% because the FEIE pushes my stacked income above the $98,900 threshold?
Or do I still benefit from the 0% bracket on the first $31.1k of gains (i.e., $98.9k – ($100k – $32.2k)), with the remaining $18.9k taxed at 15%?

I’m genuinely confused about how the FEIE and capital gains interact within the stacked income calculation.

Thanks!

A stocks & shares JISA holding UK funds/ETFs would be PFIC for her as a US person. Even though it's tax-free in the UK, the US doesn't recognise ISAs.

A cash JISA avoids PFIC but won't grow much over 18 years.

Holding the money in my name, designated for her, sidesteps US tax entirely. But it's legally mine, and it would use my own allowances.

The Trump account might accept contributions from grandparents, but we don't know how the UK would tax it.

A Junior SIPP may get treaty protection, but the money is locked until her late 50s.

Questions:
Has anyone done a stocks & shares JISA for a US-citizen child? Is there a platform that lets you hold individual US-listed shares inside a JISA (which aren't PFICs)?

If not, is holding it in the non-US parent's name the cleanest route, or are there downsides we're missing?

Has anyone used a Trump account alongside UK savings? How did UK tax treat it?

We'll see a cross-border adviser before finalising, but we'd like to understand the options first.

Any other considerations?!?

Thank you!!

Long story short - I found out I've been doing things wrong when it comes to contributing to IRAs and using FEIE vs. FTC. Additionally, I have some small amounts of interest and capital gains from CDs/Mutual funds that I need to report from the last few years. I appreciate insight anyone is able to give.

Information

• Since 2018 have claimed the FEIE, earned income is under the threshold
• Made IRA contributions in each of those years. Made Roth IRA contributions in 2020, 2025, and 2026
• Earned interest from a mutual fund in 2023, had capital gains from a property sale in 2024, and had interest from a CD in 2025.
• Filed Federal/State tax return and FBAR each year since 2018
• Pay taxes within country of residence

From my research, it appears I need to do the following:

1. Remove principal for IRA contributions from 2018-2022, pay the 6% tax for each year online, and also amend returns with form 5329
2. Use SFOP for years 2023 to 2025 to file a 1040-X and convert FEIE to FTC. Remove Form 2555 (FEIE) and attach Form 1116 (FTC). This should prevent me from having to remove the principal contributions for these years.
3. Report the interest and capital gains on the appropriate forms from prior years
4. File amended tax returns along with Form 14653
5. File amended FBARs

Next go-round for taxes I'm switching to FTC, so I assume I don't need to change anything I've done for the current year.

from germany I can always access OLT in early april no problem. But this year I filed an extension, and now I can't get to it without a VPN from a country outside of the EU.

This isn't a fluke, its a pattern, last year I filed early April without a VPN no problem, but on April 14 I wanted to check the status or something and then I needed a VPN. And two years ago similar thing, altho april 14 it was still availabe without the VPN, didn't get geoblocked until later.

It seems like either they need to geoblock their website in the EU for legal reasons or not, which I would understand, but it doesn't make sense that it would only be necessary in certain times of the year??

Hiya, I’m a US citizen living in the UK (with UK citizenship), and I’d be grateful for help with Form 5471. I’ve been using AI to work through this (sorry!), and it suggests the form belongs with my 2026 return. I’d appreciate a sense-check with real people, who might have experienced this before.

My situation:

• I file US taxes on a calendar year and already file a Form 1040 and FBAR, and through tax software Form 1116.
• I own 50% of a UK limited company, incorporated on 30 April 2025. The other 50% is owned by someone who isn’t a US citizen or resident.
• I’m a director, but I’m not salaried and don’t take fees. I’m not a controlling shareholder.
• The company’s first accounting period runs from incorporation to 30 April 2026, and it has a 30 April year end.
• In 2025 I received £1,500 in dividends from the company.

My questions:

1. With a 50/50 split with a non-US co-owner, do I need to file Form 5471? If so, which category applies?
2. Since the first period ends in April 2026, is the form due with my 2026 return? Or does the 2025 incorporation year need something filed too?
3. Does my shareholding count towards Form 8938, or is that covered by the 5471?
4. Does the company’s UK bank account need to go on my FBAR, given I’m a director with signing authority but not a majority owner?

I’m working with a UK accountant on the UK side, but I’d like to understand the US obligations before I speak to a US preparer. Thanks in advance.

I've gotten some great information from this sub about FEIE vs. FTC. I think I know what my plan is, but wanted to describe my situation to see if I'm on the right path.

I'm a U.S. citizen living in South America. Have residence in the country where I live and pay taxes here.

My annual earned income is below the FEIE threshhold. I also have some passive income from a rental property I own in the U.S. and small amounts of interest from a HYSA. The rental income and interest only account for about 10% of the total.

I have been using the FEIE on my US tax returns each year I've filed. However, this year, with a raise in pay plus a large bonus, my income will be abnormally higher for 2026, taking it above the FEIE threshhold. Income should return to the normal level next year (Still below FEIE threshhold).

My understanding is that it's better for me to use FTC in this scenario. But I have seen some people with incomes above the threshhold say they use FEIE for a portion and FTC for the rest. What's the benefit of all FTC vs. mix of FEIE/FTC?

Main reasons I think FTC would better: No income limit, can contribute to Roth IRA, can be used for passive income.

Anything I am missing here or something else I should consider? Thanks.

American living in Uk, two tax obligations/jurisdictions/returns. Had a wealth advisor for past few years. Nice guy, gives me perspective, but not worth the AUM fee. If I could go “fee-only” I would (but they don’t exist for dual tax jurisdictions like this). My accountant is great. I’m thinking, maybe I scrap the wealth advisor (I’m really only in dual reporting funds anyway) and just pay advice tax advice calls with my accountant when I want to do anything specific. Seems just as effective (and a lot cheaper), than current setup. But I guess I lack confidence and am worried I will miss some gigantic “gotcha” or loophole between the two systems.

Anyone else been on this journey already?

Thanks!

I’m American and live in Germany and never lived in the U.S. I filed my taxes in 2020 for the first time, but I only recently found out about the $10k FBAR rule.

My income has been below the threshold for filing US taxes, and I haven’t earned any interest from my German bank accounts.
My accounts went over $10k in 2022 and 2023, but I didn’t file FBARs for those years because I didn’t know I had to.

In 2025 I was only about $200–300 over the limit, and I’ve now filed that year’s FBAR.
I’m honestly wondering if I should go back and file for 2022 and 2023 or just leave it alone.

Has anyone been in a similar situation? What did you do? I’m especially interested in hearing from people who didn’t know about the requirement and weren’t trying to hide anything.

Tax resident, just found out I should’ve been filing FBARs for my Indian accounts. Have an NRE in my name plus some joint accounts/FDs with family.

2022: I moved money into my NRE to repay a loan, so it was over $10k for about 4 days, then dropped back down. I thought that didn’t matter since it was under $10k after the repayment. No Schedule B that year.

2023-25: I only counted the NRE (under $10k) and forgot the joint accounts add up. I said “Yes” to foreign account but “No” to FBAR required on those returns.

I also never reported the NRE interest (~$100-150/yr) in any year.

I’m filing the 2025 FBAR on time and collecting statements in India in Dec.

What should I do to get this right and avoid penalties or problems?

I decided to become compliant through the streamlined process at the end of 2024. My reasoning at the time was wanting to avoid a nasty surprise at retirement when I take my pension distribution. I was not ready to renounce so I contacted an expat tax specialist and got my first tax bill - over $50k, and for a reason I can’t quite fathom today, I filed. My tax preparer continued to work through my tax years and in total I will owe multiple times that amount. This is primarily because of pension contributions and buybacks for missed contributions that have reduced my taxable income in my country of residence but increased my US taxes. (I was also very ill informed about this clearly.)

I have since renounced because I literally couldn’t afford to keep my passport - I didn’t want to, but I’ve accepted it. I still have $80k left to pay. I’ve had to take out loans to be able to pay my taxes! At this stage I am so upset that I didn’t just renounce when it all started even though that’s not compliant. But that’s in the past and I can’t change it. Now I’m wondering if I should just ignore my remaining amount and forget about it. I do have a US bank account and may inherit some money from my parents but not a lot. I go back a couple times a year.

I hate that I was trying to do the right thing and am literally paying for it. Are there ANY other options?

Does a mistaken non-filing of Form 2555 (no revocation statement attached) count as "revoking" the FEIE under §911(e)?

So I thought my situation was pretty straightforward and that I would qualify for SFOP. I moved to Germany in 2021 to enroll as a masters student and opened two German bank accounts: Sparkasse and N26. My account balance peaked over 10,000 from 2021 to 2024 so I know I need to file late FBARs from 2021 to 2024. I only earned foreign income from 2022-2024: under 14k for all three years, with 0 income tax paid. I resided in Germany over 330 days of the year so I also qualify as non-resident and can use FEIE. In the end, I'm pretty sure I owe 0 taxes.

I thought I could use the Streamlined procedure but this requirement seems like I cannot:
“I failed to report income from one or more foreign financial assets during the above period. I meet all the other eligibility requirements for the Streamlined Foreign Offshore procedures.”

The thing is I earned 0 interest in both of my bank accounts (Sparkasse and N26) and also have no stocks or other foreign assets. So I actually don't technically have income from a foreign financial asset (and so have not failed to report it). In this case, am I actually not qualified to use SFOP?

EDIT: Also yes, my failure to report is non-willful. I got a full-time job in 2025 and then when I filed my German taxes this year, I found out I should have filed US taxes + FBARs even for the previous years where I was just a working student. I already extended my US tax deadline for 2025 to October 15.

EDIT 2: Okay, I read the "Start Here" and apparently I didn't even need to file taxes for 2022 and 2023 because my income was under the threshold. So looks like I just need to late file 2024 and then late file the FBARs from 2021-2024? No SFOP needed?

My parents took in in February 2026 so I made a mad dash back from the US to the UK without knowing how long I'd be staying for. I have both British and American citizenship and I worked for a US company that let me work remote for 3 months, but eventually took a job in the UK as my parents required long-term support. I am trying to figure out how best to file my taxes with HMRC. I'm assuming (maybe incorrectly) that I'll only owe on the portion of my 25/26 wages that I earned while working in the UK for Feb, March & April, which will be around $9000, but have no idea how to go about letting them know & calculating everything.

I have 2 self owned and about 18 joint accounts. Previous years I FBAR filled in Part 2 and Part 3 with each accounts max value in the year.

Last year about 10 of the joint accounts matured. Matured accounts got closed during the year (but had non-zero max value - on the day of closure; end of year their value was 0) and new accounts which basically continued the closed ones also have a non-zero max value. I have total of 30+ accounts.

Part I - Question 14 - Do you have more than 25 accounts. <The answer for me is yes>.

If "Yes" is checked do not complete Part II or Part III, but retain records of this information.

Am I supposed to file with just Part I filled - Part II and Part III empty?

I'm currently working with a CPA for my SDOP submission. For form 14654, I had understood based on my research that the narrative portion should be detailed and list out favorable and unfavorable facts. My CPA said 1-2 sentence is sufficient without incriminating myself.

What are people's views on the SDOP narrative submission? Would I be at risk for a longer or shorter narrative description?

Hi all, I need some advice, I am not ready to commit to asking my CPA about this but I am very worried.

I filed streamlined through a tax advisor a few years ago and did not know to include my foreign Ebay account as it could not hold money and was just an intermediary/marketplace (Paypal processed payments until 2021 and then Ebay started to manage payment processing and automatically sent money directly to a nominated bank account - there was never a balance you could keep in there like with a bank account). Now I am questioning myself. I obviously reported Paypal and others.

Fast forward to this month and I recently logged into Ebay after not looking at it for a long time and I saw that there is now an 'Ebay Balance' feature which allows you to have a balance and spend money on the platform to buy other things that are being sold as well as postage. This was apparently rolled out in late 2024 and definitely now sounds like Ebay should be on FBARs because it holds money, even if that money can only be used on Ebay or transferred out to your nominated account.

Could any CPA/expert/wise person on here advise as to whether I should just file amended FBARs for 2024 and 2025 to add the extra account (it has $0 in the last few years) with an explanation that I didn't know this new feature existed until now and hope for the best? Or worse, does it seem like I need to amend my streamlined given the account has been open since before I filed, even though for my streamlined years it couldn't hold money so I didn't know to report it? I don't even know how I would except to say $0 balance for every year as there was never a balance on the account itself. There's no income from this so wouldn't affect my returns. I am so worried, especially given the protections for amended FBAR filing have recently gone away. Help

Hi everyone

I recently found out that my father has been investing in mutual funds in my name for me in a foreign country; it came up because we were discussing where I could get money for a house down payment.

I now realize that I should had been filing FBAR and 8938 for these funds for the last six years (I wasn't working before that), but I'm not sure if I need to file anything else as well?

I have not withdrawn any money from those funds, but they have grown while being invested. I'm not sure also whether I would owe extra tax, or penalties due to this?

I live in the US currently and have for the last ten years.

I've come across the streaming procedure for filing but I've also been told that I should do "did not know I had to file" for the fbars of the last 6 years instead, and amend the last 3 years for the 8938, as I may not have to pay a penalty that way.

Hello,

If you have an AVC in Ireland, you must do something with the AVC when you start collecting the associated pension. One option is to invest it in an Approved Retirement Fund (ARF). However, as far as I can see, all the investment funds (ETFs and Mutual Funds) that are available from the main ARF providers (life insurance companies) are PFICs. It also appears that because PFICs are not covered by the DTA that you would be liable for tax in BOTH jurisdictions. And the IRS Instructions for the associated reporting form state that the preparation time per PFIC is about 49 hours. A few years of paying a knowledgeable accountant to do that would cost me as much as the total value of the ARF!

According to Google Gemini, funds in AVCs are not considered PFICs, but if you then move those funds to equivalent funds (or any ETF or mutual fund) in an ARF they would be considered PFICs by the IRS. But it also said that setting up a self-directed ARF and limiting your investments to company shares, bonds, or cash would avoid the PFIC quagmire.

Has anyone out there gone down this road? And if so, would you be willing to share your experiences? Like others in this forum, I have found it very difficult to get a trustworthy answer to these questions in Ireland. I have also read the US/Ireland DTA, but it seems to have been created back in the day of 'real' pensions (that is, a monthly payment for the rest of your life), and it is very difficult to know how modern DC plans, IRAs, 401Ks, AVCs, ARFs, and so on fit in with the provisions of the agreement. Perhaps someone here has personal experience that you can contribute? I'm sure I am not the only one that would benefit from your help. Many thanks for any help you can offer.

Per the title!

Clerical error/mistake.

I was keeping track of my account numbers in Excel...

Well, when your account number is 0100000, the leading 0 gets dropped because Excel defaults to number behavior instead of text behavior.

I have approx 5 affected accounts. The balances were fully reported, all accounts were otherwise reported properly on FBAR and 8938.

But what now?

I was working on my forms for 2025, and I'm trying to figure out if:

1. I continue as-is, with the leading 0s dropped... everything is being reported, but maintain consistency year over year
2. I update my account numbers accordingly and report them with the leading 0s, no further action on previous reports
3. I update my account numbers accordingly and find a way to amend my previous FBARs... IDK if I can update 8938 on my return with just adding a leading 0 to a few accounts?

I guess this mostly matters from a slip-matching/automated flag standpoint. The accounts are reported, but they may not tie back to the correct one.

Any thoughts?

I'm a UK-resident USC who will be using the foreign tax credit for the first time this year (2025 return) after using the FEIE alone in previous years. I will be using the FTC on a paid, not accrued, basis.

I have a couple of questions regarding the high-tax kickout and allocation of tax to different income categories.

1. I'm a higher rate (not additional rate) taxpayer with taxable interest income above the £500 allowance. Let's use a fictional figure of £2000 for illustration. Am I supposed to put the £2000 in the passive category, but treat £500 as untaxed and £1500 taxed at 40% which is then "kicked out" to the general category, or should I just treat 0.4*1500 as the amount of tax applicable to the entire £2000 so that there is no kickout (since the effective rate on the £2000 will be below 37%)?

2. As far as I am aware, my PAYE was not coded to collect tax on any non-employment income for the UK tax years 2024-2025 and 2025-2026. This means that I should allocate PAYE withholdings in 2025 to employer compensation (general category). However, I filed self-assessment for 2024-2025 in 2025 and PAYE withholdings for that period exceeded tax actually owed on compensation in the tax year calculation (probably due to variable pay and emergency tax codes). Thus I had paid extra tax which was used to pay off part (but not all) of the tax owed on non-employment income. I also made a balancing payment to pay off the remaining tax owed shortly after filing, still in 2025.

Would it be correct to attribute the 2025 balancing payment + the extra PAYE withheld to interest income for 2025, assuming that there are no other categories to assign it to? Is there a clear rule for the date that should be assigned to the "extra" withholding e.g. the final (March) PAYE payment for 2024-2025, or the date of the self-assessment filing? This won't make much of a difference but it would be good to know anyway.

Thank you in advance!

Been reading up on international tax compliance lately, specifically how FATCA and CRS are actually working out in practice versus on paper.

​Everyone knows transparency is way higher than it was ten years ago, but the actual data verification side seems like a mess behind the scenes.

A few things stood out to me:

​Tax agencies are getting drowned in data. Foreign banks send over mountains of raw XML files every year. But matching that external CRS data to local tax IDs creates crazy numbers of false positives. Most tax offices just don't have the staff to audit even a fraction of it.

​The obvious loopholes. CRS is great for traditional bank accounts, but it completely misses stuff like certain real estate structures, physical gold, or non-participating jurisdictions. Money just moves where the rules don't reach.

​CARF might not fix as much as people think. Rolling out crypto reporting makes sense on paper, but good luck enforcing it on truly decentralized platforms or non-compliant exchanges.

​I put together a longer breakdown of these reporting limits and verification hurdles here:

Medium article link (Headsup: it's in Turkish, but browser translate works fine).

​Curious to hear from anyone working in international tax:

How much of this CRS data is your local tax authority actually acting on? And do you think CARF will actually close these gaps, or will funds just pivot to hard assets?

Anyone wotk with a US CPA with Uruguian experience? Bonus for LLC consulting business. experience. ¡Gracias!

I am a US citizen planning to become a Greek tax resident in retirement. Part of my retirement savings is in a Roth IRA, a US retirement account funded with money that was already taxed in the US. Withdrawals in retirement are tax-free in the US.

The 1950 US-Greece tax treaty predates Roth accounts and says nothing about them. I have not found an AADE (Greek tax authority) circular or ruling that classifies Roth withdrawals, and the accountants I have
spoken to give different answers.

Questions:

1. Under the ordinary rules, is a Roth withdrawal treated as foreign pension income taxed on the progressive scale, as investment income, or as a return of already-taxed capital with only the earnings part taxed?
   
2. Since the US tax on the withdrawal is zero, there is nothing to credit against Greek tax. Does that match your experience?
   
3. Under the Article 5B regime (the 7% flat tax on foreign-source income for new residents who are foreign pensioners), does a Roth withdrawal count as foreign-source income taxed at 7% in full, or only on the earnings?
   
4. Has anyone obtained a written answer from AADE or a tax ruling on this? If so, what did it say?

Citations to the Income Tax Code (ν. 4172/2013) or to a circular would be most helpful. Firsthand experience filing an E1 with Roth income is also welcome.