7 Guides across 1 job. Each Guide is authored by an accountant; the ones more colleagues stand behind rise to the top.
Tier 2 US federal content skill for the dual foreign financial account disclosure regimes — FinCEN Form 114 (FBAR) under 31 USC §5314 and Form 8938 (FATCA) under IRC §6038D. Covers tax year 2025 including the $10,000 aggregate FBAR threshold (per Bittner 2023 non-willful penalty is per-form not per-account), Form 8938 specified person and SFFA thresholds ($50k/$100k/$200k/$400k tiers), the differences in coverage (signature authority for FBAR, ownership for 8938, foreign mutual funds for 8938 only), willful and non-willful penalty severity, and the Streamlined Foreign Offshore / Domestic Offshore compliance paths for catching up.
The US taxes citizens wherever they live. What that actually means when you move abroad: the FEIE vs Foreign Tax Credit decision, FBAR and FATCA reporting, the PFIC and foreign-company (GILTI/5471) traps, sticky states, Social Security and totalization, and — for those who go all the way — the §877A exit tax on renouncing. Sequenced by destination type: zero-tax (UAE/Gulf) vs high-tax (EU).
US tax residency for non-US-citizens: substantial presence test, green card test, first-year election, closer connection exception, treaty tie-breaker, dual-status returns. Trigger on: "US tax resident alien", "substantial presence test", "183-day US test", "green card tax residency", "first year election US", "closer connection exception", "US dual status return", "non-resident alien US", "treaty tie-breaker US", "moving to US taxes", "leaving US taxes". US citizens are always resident — this skill covers non-citizens only.
US anti-deferral rules for US persons owning foreign corporations: Controlled Foreign Corporation status (IRC §957/§951(b)), Subpart F income (§951/§952), GILTI (§951A) and the §250 deduction, the §962 election to be taxed at corporate rates with deemed-paid credits, the high-tax exception, and Form 5471 filing. Produces a working paper and a reviewer brief — not a filed return. MUST load alongside cross-border-tax-workflow-base.
US foreign-account and foreign-asset reporting for US persons: the FBAR (FinCEN Form 114) and FATCA (Form 8938, IRC §6038D). Covers the $10,000 FBAR aggregate threshold, the higher Form 8938 thresholds, who must file, what each regime counts, deadlines, the willful/non-willful penalty regime, and the streamlined and delinquent-FBAR remediation paths. Produces a working paper and a reviewer brief — not a filed return. MUST load alongside cross-border-tax-workflow-base.
Tier 2 US federal-level content skill for multi-state residency, domicile, part-year residency, statutory residency (e.g. NY 183-day + abode rule), nonresident income sourcing, the convenience-of-the-employer rule (NY, NJ, CT, PA, NE, AR — partially), equity compensation allocation (stock options grant-to-exercise, RSU grant-to-vest), §4 USC 114 federal preemption of pension source taxation, resident credit for taxes paid to other states, reciprocal-agreement states (PA-NJ, OH-WV-KY-IN-MI-PA-VA), and post-COVID telework sourcing. Covers tax year 2025.
Tier 2 US federal international tax content skill for §951A GILTI / post-2025 NCTI, §250 FDII / post-2025 FDDEI, §59A BEAT, and surviving Subpart F. Covers tax year 2025 including the 50% §250 GILTI deduction, 37.5% FDII deduction, 10% BEAT rate, §962 election, Forms 5471/8992/8993/8991, §965 final installments, and OBBBA P.L. 119-21 post-2025 mechanics: 40% NCTI deduction, 33.34% FDDEI deduction, 90% NCTI deemed-paid FTC, QBAI/NDTIR removal after 2025, and 10.5% BEAT rate with protected-credit treatment.