International Tax

Controlled Foreign Corporation A controlled foreign corporation, or CFC, is a foreign corporation that is sufficiently owned by certain US shareholders under US tax rules. Dual-Status Alien A dual-status alien is a taxpayer treated as both nonresident and resident during different parts of the same tax year under US tax rules. Expatriate Tax Expatriate tax is the broad term for the US and foreign tax issues faced by people living or working outside their home country. FATCA FATCA usually refers to Form 8938 and related rules requiring reporting of certain specified foreign financial assets. FBAR FBAR is the common name for FinCEN Form 114, which reports qualifying foreign financial accounts when the total value exceeds the filing threshold. Foreign Earned Income Exclusion The foreign earned income exclusion is a rule that may let qualifying taxpayers exclude certain foreign earned income from US taxation, subject to annual limits and residency tests. Foreign Housing Exclusion The foreign housing exclusion is the rule that may let certain qualifying taxpayers exclude or deduct part of eligible foreign housing costs, subject to specific limits. Foreign Tax Credit The foreign tax credit is a credit that may reduce US tax when income has already been taxed by a foreign country. GILTI GILTI stands for global intangible low-taxed income, a US tax regime affecting certain owners of controlled foreign corporations. Nonresident Alien A nonresident alien is an individual who is not treated as a US tax resident under the applicable residency rules. PFIC PFIC stands for passive foreign investment company, a classification that can trigger complex US tax and reporting rules for certain foreign pooled investments. Residency Test A residency test is the legal test used to determine whether a taxpayer is treated as resident or nonresident in a jurisdiction for tax purposes.