“International tax is not general tax with an overlay. It is a distinct body of doctrine, rules, and practical procedures that surprises experienced domestic practitioners repeatedly throughout a cross-border engagement.”
The canonical technical reference. Every code section (§877A, PFIC §1291 / §1296 / §1295 QEF, GILTI / §250 / §245A / §962, FIRPTA, §1446(f) PTP, §884 BPT), every form (5471, 8938, 3520, 3520-A, FBAR, 8854, 708), every computation methodology, explained once. Holds the outbound regime (US persons with foreign assets), the inbound regime (non-US persons with US assets), and cross-jurisdictional family work (non-US spouses, multi-jurisdictional estates, expatriation) together for the sophisticated reader. Integrates FBAR / FATCA, PFICs, CFCs / Subpart F / GILTI, FIRPTA, expatriation under §877A, QDOT, treaty article walks for US-Canada / UK / India / China / Mexico, and the Streamlined Compliance Procedures. Cited cover-to-cover. With a 22-tab companion Excel workbook and six free decision tools. Pairs with the Cross-Border Wealth Playbook (the cases + planning lens) for the complete cross-border practice.
The market for international-tax references bifurcates between treatise depth (Doernberg, BNA Portfolios, $300+) and consumer-facing expat-blog content (Greenback, TFX, free). What's missing is the integrated single-volume reference for the sophisticated reader who needs the orienting framework before engaging specialty counsel. That's where this guide lives.
FBAR + FATCA, PFICs, CFCs / Subpart F / GILTI, foreign trusts, US expatriate playbook, §245A DRD, §250 FDII, GILTI high-tax exception.
Pre-immigration playbook, FIRPTA, $60K estate-tax trap for non-US persons, the NRA investor, §884 branch profits tax, §1446(f) PTP withholding, FATCA chapter-4 withholding.
Non-US spouses (QDOT, §6013(g)), multi-jurisdictional estate planning, expatriation under §877A with 24-36 month planning window, §2801 recipient back-half, country-specific treaty walks.
Each free tool is calibrated to a specific chapter and produces a working number you can take to a meeting. Built to standalone — you don't need to read the guide first. Day-count residency questions are handled by the Tax-Residency Day Counter in the Cross-Border Wealth Playbook tool layer (US SPT + UK SRT + Canada 183, with dual-residence warning) — see the disambiguation note below.
Which PFIC regime delivers the lowest US tax on your foreign mutual fund? §1291 default vs §1296 MTM vs §1295 QEF outcomes side-by-side.
CFC tested income + QBAI + NDTIR + GILTI inclusion + §962 election analysis (21% corp rate + 50% §250 + 80% FTC).
How much US tax to renounce citizenship? Mark-to-market exit tax + three covered-expatriate tests + IRA deemed-distribution.
Do you need to file an FBAR or Form 8938? By filing status, residence, and aggregate foreign account balances.
SFO (0% penalty) vs SDO (5% penalty) eligibility wizard. Five-question flowchart for retroactive non-willful compliance.
For day-count residency: US SPT + UK SRT + Canada 183 + generic 183, with dual-residence warning. Lives in the Cross-Border Wealth Playbook tool layer; subsumes our retired standalone SPT calculator.
The two cross-border guides are deliberately differentiated — one technical reference, one applied-planning lens. Most cross-border clients eventually need both.
| This guide (IntlTax) | Cross-Border Wealth Playbook | |
|---|---|---|
| Lens | Technical reference — code sections, forms, computations | Applied planning — cases, corridors, life stages |
| Core spine | FBAR/FATCA, PFIC, CFC/GILTI, FIRPTA, §877A exit tax, Streamlined Procedures, QDOT, treaty article walks | Residence/source/situs framework, RBI/CBI, return-home, matrimonial, the global family office, 5 recurring family cases on 5 continents |
| Reader at the desk | CPA / EA adding international competency, sophisticated reader engaging counsel | Internationally mobile family principal, rising-gen heir, cross-border private-client attorney, international wealth manager |
For the applied-planning lens — named families, country corridors, and life stages — see the Cross-Border Wealth Playbook. The two compose into the complete cross-border practice, each sold on its own.
Each tab is self-contained. Blue cells are inputs you type; black cells calculate; yellow cells are annual assumptions (rates, indexed thresholds) you confirm at year-end. Tabs: