Treaty-Led
Strategy Design
The US is one of the few countries that taxes its citizens on worldwide income, no matter where they live or work. If you earn abroad, that creates a real risk of double taxation. The tools that prevent it are treaty analysis, exclusions, and foreign tax credits, and each has to be applied correctly for your situation.
Our cross-border practice advises US individuals moving abroad and foreign nationals investing in the US. The core of the work is reconciling your US obligations with the rules of the country where you live, so the two systems do not tax the same income twice.
How we deliver this service.
A rigorous, phase-driven process ensures nothing is missed and every position is defensible.
Residency & Nexus Audit
We determine your tax residency status under US domestic law and 'tie-breaker' treaty rules to identify your primary filing obligations.
Global Asset Mapping
We review all foreign bank accounts, pensions, and business interests (CFC/PFIC) and map the US reporting each one requires.
Treaty Analysis
Our team reviews applicable US tax treaties to identify relief for specific income types, including pensions, social security, and royalties.
Tax Modeling & Exclusion
We model the Foreign Earned Income Exclusion (FEIE) against Foreign Tax Credits (FTC) to see which saves you more.
Strategic Catch-up
For taxpayers with historical omissions, we design a catch-up strategy using Streamlined or Delinquent filing procedures.
Continuing Compliance
We manage the annual filing of Form 1040/1040-NR and all international disclosure forms (5471, 8865, 8621, 3520).
Outbound Strategy
Reducing the US tax bill for expats.
Living abroad doesn't mean paying double tax, but it does mean filing twice. We use the Foreign Earned Income Exclusion (Section 911) and the Foreign Tax Credit (Section 901) to remove US tax on foreign-sourced income. The choice between credit and exclusion matters: in high-tax countries, the credit almost always produces a better long-term result because unused credits carry forward.
We also handle the US reporting for foreign pensions (SIPPs, RRSPs, Superannuation) and check that your local investments don't fall into the Passive Foreign Investment Company (PFIC) rules, which carry punishing US tax rates.
Expat focus: Section 911 (Exclusion), Section 901 (Credits), Form 2555, Form 1116, and PFIC (Form 8621) mitigation.
Tailored for every client profile.
Inbound Compliance
Withholding relief for inbound investors.
Foreign nationals investing in US real estate or businesses run into withholding rules under FIRPTA (Section 1445) and standard NRA withholding (Section 1441). Without a treaty position, up to 30% of your gross income or 15% of your sales price can be withheld at the source.
We help foreign investors get ITINs, file Form 1040-NR, and apply tax treaties to reduce or eliminate withholding. We also structure inbound investments through blockers or tiered entities to limit US estate tax exposure for non-resident aliens, whose exemption starts at just $60,000.
Inbound focus: Form 1040-NR, FIRPTA (Form 8288), ITIN applications (W-7), and US estate tax planning for high-net-worth NRAs.
Expatriation Strategy
Leaving the US tax system cleanly.
Giving up a US passport or green card (expatriation) is a major tax event. Permanent residents who have held a green card for 8 of the last 15 years are 'Long-Term Residents' (LTR) and may face the Section 877A 'Exit Tax', which treats all global assets as sold on the day before departure.
We run the pre-departure modeling that determines 'Covered Expatriate' status, and where it helps, use gifts or trusts to bring your global net worth below the $2M threshold. The aim is an exit that is compliant and costs you as little as possible.
Exit focus: Section 877A Exit Tax, Form 8854, 'Covered Expatriate' status modeling, and pre-departure wealth transfer.
Living or investing across borders?
Double taxation is avoidable with the right treaty positions. Talk to us before the two systems take a bite out of the same income.
Specific deliverables, precisely documented.
“The US tax system follows its citizens around the world. We make sure everything you hold abroad is reported correctly and taxed no more than it has to be.”
Technical clarifications.
Answers to the most frequently asked questions about how this service works in practice.
In most cases, no. Through the use of Foreign Tax Credits and Tax Treaties, we can usually eliminate double taxation. You will, however, have to *file* in both countries and technically reconcile the different tax years and rules.
When two countries claim you as a resident under their domestic laws, a tax treaty 'tie-breaker' rule determines your primary residence based on factors like your permanent home, center of vital interests, and nationality.
The penalties for failing to file an FBAR or Form 8938 are severe, starting at $10,000 per violation. We help taxpayers come forward voluntarily through catch-up programs to minimize or eliminate these penalties.
The US generally taxes foreign pension growth unless a specific treaty provides for deferral. We analyze your local pension structure (e.g., UK SIPP, Aus Super) to determine the US tax treatment of contributions and growth.
A Passive Foreign Investment Company is any foreign corporation where 75% of income is passive. Most foreign mutual funds and ETFs are PFICs, and they are subject to very high US tax rates unless specialized 'elections' are made.
Related services.
Two Tax Systems, One Team
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