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Tax court small case procedure offers a faster, simpler path to dispute IRS deficiencies under $50,000. Learn the rules, trade-offs, and risks.
Nonresident aliens face U.S. gift tax on U.S. real estate and tangible property, but not on intangibles like stocks. Here is the framework and the
U.S. property left to foreign children triggers estate tax, marital deduction limits, and ongoing income tax for the heirs. Here is the planning framework.
Foreign private pensions are FBAR-reportable when the $10,000 aggregate threshold is met. Government social security generally is not. Here is the distinction.
Foreign pensions trigger up to six U.S. reporting forms per year. Here is the complete framework and how the pieces apply by country and plan
Canadian RRSPs get automatic treaty-based deferral under Rev. Proc. 2014-55. Here is how the U.S. tax treatment works and what reporting still applies.
Australian superannuation has U.S. tax consequences that often surprise members. Here is the classification, the PFIC issue, and the disclosure paths.