Guide · Tax
International and Cross-Border Tax: A Comprehensive Guide to FBAR, FATCA, and Foreign Income
26 U.S.C. § 6114
- Type
- Guide
- Jurisdiction
- National
- Date
- 2026-06-21
- Topic
- Tax
This guide states the law governing the taxation and reporting of cross-border income and assets by United States persons. Part 1 covers status — citizenship, permanent residence, substantial presence, treaty tie-breakers, and dual-status years — because everything else depends on it. Part 2 covers worldwide taxation and the relief provisions, including the foreign earned income exclusion, the foreign tax credit, treaties, and the saving clause that limits their benefit to citizens. Parts 3 through 5 cover the FBAR, the FATCA individual and institutional regimes, and the information returns required for foreign corporations, partnerships, trusts, and gifts. Parts 6 and 7 cover the anti-deferral regimes for passive foreign investment companies and controlled foreign corporations and the expatriation tax. Parts 8 and 9 cover penalties, willfulness, limitations, and the four correction procedures, with the criteria that determine which is available. Later parts address enforcement, prospective planning, and the state residency rules that frequently produce liability where federal law does not.
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