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Articles

Articles

Form 8621 Non-Filing Risk: Why PFIC Compliance Deserves More Attention

Explanation how missing Form 8621 filings for PFIC investments can expose U.S. taxpayers and tax professionals to indefinite IRS statute-of-limitations risk, complex compliance burdens, and growing audit exposure as international reporting enforcement increases.

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Navigating State Homicile For Expats

An outline of key factors states consider in determining taxpayer domicile, with recommendations on steps practitioners can take to help clients reduce the risk of state tax liability.

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The Trouble with QEF Reporting

Key issues surrounding the sale of a fiscal year qualified electing fund (QEF) by passive foreign investment companies (PFICs) and related tax considerations.

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The Nightmare of PFICs at the State Level

Frequently asked questions intended to make tax professionals think about what their clients with state residency or domicile who also own a PFIC are facing.

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Ownership in Passive Foreign Investment Companies

A look at the time-consuming nature of IRS Form 8621 reporting for PFIC shareholders, and how Expat Tax Tools’ services and software help simplify compliance and reduce the burden on taxpayers.

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Alleviating State Double Foreign Taxation

Tax strategies and tips to alleviate double taxation on foreign income at the state level, using tax relief provisions offered by the states to offset taxation by a foreign jurisdiction.

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Retroactive QEF Election

The IRS released Revenue Procedure 2026-10, providing long-awaited clarity for passive foreign investment company (“PFIC”) shareholders seeking private letter rulings (PLRs) to obtain retroactive qualified electing fund (“QEF”) elections.

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