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Expatriate

Tax guidance, financial planning, and accounting advice for Americans living abroad

El Salvador Now Asks Just 90 Days a Year: A Freelancer's Guide to the New Residency Math

Since March 31, 2026, El Salvador's Decreto 531 requires temporary residents to spend only 90 calendar days a year in the country instead of roughly nine months. Here is how the three main residency routes compare, what territorial tax and the U.S. foreign earned income exclusion actually cover, and the ledger habits that keep presence days, income sourcing, and renewal files audit-ready.

Form 8858 for Foreign Disregarded Entities and Foreign Branches: A Practical Filing Guide for Expat Founders, Multinationals, and U.S. LLC Owners Abroad

Form 8858 reports foreign disregarded entities and foreign branches on a U.S. return, and missing one carries a $10,000 penalty per entity per year that can snowball to $50,000 after IRS notice. This guide covers who must file, Schedules C through M, Section 987 currency calculations, the Schedule K-2/K-3 box 11 connection for Category 6 filers, and the four paths back into compliance.

Section 7701(b) Substantial Presence Test for Foreign Entrepreneurs: The 183-Day Formula, Closer Connection, and Treaty Tie-Breakers

A practical walkthrough of IRC Section 7701(b) for globally mobile founders — the 31-day floor, the weighted three-year 183-day formula, exempt-individual rules, the closer connection exception (Form 8840), and treaty tie-breakers (Form 8833) — with a worked example showing how 130 U.S. days in 2026 can trigger worldwide taxation.

Streamlined Filing Compliance Procedures: How Non-Willful US Taxpayers Catch Up on FBAR, Form 8938, and Three Years of Late Returns Without Crushing Penalties

How non-willful US taxpayers use the IRS Streamlined Filing Compliance Procedures to catch up on FBAR, Form 8938, and three years of late returns—zero penalty under SFOP for taxpayers abroad, a one-time 5% miscellaneous offshore penalty under SDOP for domestic filers, plus what the non-willfulness certification must demonstrate.

GILTI and the Section 962 Election: How US Shareholders of Foreign Corporations Can Slash Their Tax Bill

A Section 962 election lets US individual owners of a controlled foreign corporation be taxed on GILTI/NCTI at corporate rates, cutting the effective US rate from up to 37% to roughly 12.6% in 2026. The OBBBA reduced the Section 250 deduction to 40%, eliminated the QBAI carve-out, and raised the indirect foreign tax credit cap from 80% to 90% — but PTEP rules can still trigger a second layer of US tax when earnings are eventually distributed.

Form 5471 Decoded: A US Shareholder's Guide to Filing Categories, Schedules, and Avoiding Six-Figure Penalties

Form 5471 carries automatic $10,000-per-corporation initial penalties capped at $60,000 per year for U.S. persons who own, control, or serve as officers of foreign corporations. Covers the five filing categories, modular schedules, GILTI's rename to NCTI for tax years beginning after December 31, 2025, and the Streamlined and Delinquent Submission routes back into compliance.