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U.S. Tax Insights

A collection of articles on U.S. tax matters for clients with cross-border interests. We cover common questions, filing requirements, and tax considerations that arise when U.S. tax meets international circumstances.

For general information only and not intended as tax advice.

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The $60,000 Trap: US Estate Tax for Non-US Investors Who Own US Stocks

US–Asia Aug 28, 2026

The $60,000 Trap: US Estate Tax for Non-US Investors Who Own US Stocks

Non-US investors pay no US capital gains tax — but face 30% dividend withholding and a US estate tax of up to 40% on US shares above just US$60,000. Canada's treaty largely protects its residents; Hong Kong and Singapore have none.

MPF and CPF Under US Tax Rules: How Hong Kong and Singapore Retirement Savings Are Treated

US–Asia Aug 11, 2026

MPF and CPF Under US Tax Rules: How Hong Kong and Singapore Retirement Savings Are Treated

Hong Kong's MPF and Singapore's CPF get no US treaty recognition — but that does not mean the growth is taxed every year. How the §402(b) employees' trust rules tax the employer contribution up front and defer the internal growth until withdrawal.

When Foreign Life Insurance Fails the US Test: Section 7702 and Cash-Value Policies

Individuals & Expats Aug 6, 2026

When Foreign Life Insurance Fails the US Test: Section 7702 and Cash-Value Policies

Popular Hong Kong and Singapore savings-and-investment policies rarely meet the US definition of life insurance. Here is how §7702 taxes the inside build-up, the 1% excise tax on foreign premiums, and the PFIC and reporting traps that follow.

RRSP and RRIF Withdrawals: The US-Taxable Amount and Your Foreign Tax Credit

US–Canada Aug 8, 2026

RRSP and RRIF Withdrawals: The US-Taxable Amount and Your Foreign Tax Credit

A US citizen drawing on an RRSP or RRIF faces tax on both sides of the border. How to work out the US-taxable portion, claim the Canadian withholding as a foreign tax credit, and see where residual US tax or stranded credit still bites.

PFICs: Why Americans Abroad Should Fear Ordinary Mutual Funds

Individuals & Expats Feb 2, 2026

PFICs: Why Americans Abroad Should Fear Ordinary Mutual Funds

The passive foreign investment company rules turn everyday non-US mutual funds and ETFs into the most punitively taxed assets an American can own. How to recognise a PFIC, what it costs, and the elections that defuse it.

The American in Hong Kong: A US Tax Survival Guide

US–Asia May 25, 2026

The American in Hong Kong: A US Tax Survival Guide

Hong Kong's low, territorial tax system is a blessing locally and a complication federally. What US citizens in Hong Kong need to know about the 1040, the missing treaty, MPF accounts, and local companies.

Canadians Moving to the US: The Pre-Move Tax Checklist

US–Canada Mar 30, 2026

Canadians Moving to the US: The Pre-Move Tax Checklist

The most valuable US tax planning for Canadians happens before the moving truck arrives. Residency start dates, departure tax, RRSPs and TFSAs, and the elections that expire the day you become a US resident.

Canadians Owning US Real Estate: Rental Income, FIRPTA and the Exit

US–Canada Jun 1, 2026

Canadians Owning US Real Estate: Rental Income, FIRPTA and the Exit

From Florida condos to Arizona rentals, Canadian owners of US property face a defined set of US filings — the 1040-NR, the net-rental election, ITINs, and FIRPTA withholding at sale. A walkthrough of the lifecycle.

FBAR vs Form 8938: Two Reports, One Set of Accounts

Compliance & Reporting Feb 16, 2026

FBAR vs Form 8938: Two Reports, One Set of Accounts

The FBAR and Form 8938 both report foreign financial accounts, are filed under different laws, on different forms, with different thresholds — and filing one does not satisfy the other. A side-by-side guide.

Claiming the Foreign Tax Credit for Japanese Taxes: What Counts and What Does Not

US–Asia Aug 14, 2026

Claiming the Foreign Tax Credit for Japanese Taxes: What Counts and What Does Not

A senior cross-border CPA breaks down which Japanese levies a US citizen can credit on Form 1116, which cannot, and how the inhabitant tax timing mismatch quietly distorts your foreign tax credit.

Foreign Earned Income Exclusion vs Foreign Tax Credit: Choosing Your Weapon

Individuals & Expats Jan 26, 2026

Foreign Earned Income Exclusion vs Foreign Tax Credit: Choosing Your Weapon

Americans abroad have two main tools against double taxation — the FEIE and the foreign tax credit. The right choice depends on where you live, what you earn, and what you plan next. A practical comparison.

The Foreign-Owned US LLC: Form 5472 and the $25,000 Mistake

Businesses & Entities Apr 27, 2026

The Foreign-Owned US LLC: Form 5472 and the $25,000 Mistake

Non-US founders and investors love the Delaware LLC — easy to form, cheap to run, and often tax-free. What the formation websites omit: an annual Form 5472 filing with a US$25,000 penalty for silence.

Foreign Trusts, Forms 3520 and 3520-A: The Reporting Nobody Warns You About

Foreign Trusts May 4, 2026

Foreign Trusts, Forms 3520 and 3520-A: The Reporting Nobody Warns You About

Foreign trusts — and arrangements the US treats as foreign trusts — carry some of the steepest automatic penalties in the tax code, and they reach inheritances, gifts and pension plans ordinary families never thought of as trusts.

Form 5471: When Your Foreign Company Becomes the IRS's Business

Businesses & Entities Mar 16, 2026

Form 5471: When Your Foreign Company Becomes the IRS's Business

US persons who own foreign corporations — a Hong Kong limited, a Canadian CCPC, a Singapore Pte Ltd — face Form 5471 reporting and the CFC anti-deferral rules. What triggers the filing, what it costs to miss, and the elections that help.

Moving to the US from Asia: Pre-Immigration Tax Planning That Actually Works

US–Asia Apr 6, 2026

Moving to the US from Asia: Pre-Immigration Tax Planning That Actually Works

For families moving from Hong Kong, Taiwan, Japan or Singapore to the United States, the months before US residency begins are a one-time planning window. What closes on day one — and what to do while it is still open.

The 70% Tax Trap: How PFICs Create Double Taxation for Americans in Canada

US–Canada Aug 1, 2026

The 70% Tax Trap: How PFICs Create Double Taxation for Americans in Canada

For US citizens living in Canada, an ordinary Canadian mutual fund can trigger the punitive PFIC regime, stacking Canadian capital-gains tax on top of a US throwback charge and interest to reach a combined effective rate above 70%.

Defusing the PFIC Bomb: QEF vs. Mark-to-Market Elections

Individuals & Expats Aug 4, 2026

Defusing the PFIC Bomb: QEF vs. Mark-to-Market Elections

Foreign mutual funds and ETFs are almost always PFICs, and the default US tax regime is designed to hurt. Here is how QEF and mark-to-market elections work, and why acting in year one changes everything.

The Streamlined Filing Compliance Procedures: A Clean Way Back

Compliance & Reporting Mar 9, 2026

The Streamlined Filing Compliance Procedures: A Clean Way Back

Years behind on US tax filings while living abroad? The IRS streamlined procedures let non-willful taxpayers catch up with three years of returns and six years of FBARs — often with no penalty at all. Here is how they work.

TFSAs, RESPs and FHSAs: How the US Taxes Canadian Registered Accounts

US–Canada May 11, 2026

TFSAs, RESPs and FHSAs: How the US Taxes Canadian Registered Accounts

Canada's favourite tax-sheltered accounts lose their shelter at the border. How the IRS treats TFSAs, RESPs, FHSAs and RRSPs in the hands of US persons — and what to do about it.

US Citizens Living in Canada: What You Still Owe the IRS

US–Canada Apr 20, 2026

US Citizens Living in Canada: What You Still Owe the IRS

A plain-language overview of the US filing obligations that follow American citizens and green card holders to Canada — the annual return, the FBAR, and the traps hiding inside ordinary Canadian accounts.

The US–Japan Estate Tax Treaty: Protecting Cross-Border Families from Double Death Tax

US–Asia Aug 13, 2026

The US–Japan Estate Tax Treaty: Protecting Cross-Border Families from Double Death Tax

A Japanese national holding US shares can face US estate tax on assets already caught by Japan's inheritance tax. The 1954 treaty answers with a pro-rata unified credit and coordinating credit rules — here is how the relief actually works.

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