Cross-border tax for US persons is the practitioner conversation with the highest ratio of complex facts to available free references. This is the reference that closes that gap. Seven sourced walkthroughs on the questions that keep coming up: Puerto Rico Act 60, GILTI, Form 8938 vs FBAR, PFIC rules, where the US high earner actually ends up, the §877A cost of surrendering US citizenship, and the single-page overview for US persons living abroad. Free. Refreshed quarterly.
Cross-border tax for US persons is uniquely complex because the United States taxes on citizenship, not residence. That single fact reshapes the practitioner conversation for every US citizen and green-card holder who lives abroad, marries a non-US person, holds a foreign business interest, or considers relocation. It also generates a set of specific questions that recur constantly: Do I file FBAR or Form 8938 or both? What actually happens if I move to Puerto Rico? How does GILTI hit my foreign subsidiary? What does §877A cost if I renounce?
The Baratelli International Tax Reference is the practitioner-grade layer for these questions. Every page walks the applicable IRC section, treasury regulation, or treaty article; sources the statutory constants for the current year; and closes with a decision framework rather than a marketing pitch. The paid flagship — the International Tax & Cross-Border Wealth guide — is where the applied casework lives.
The reference refreshes quarterly (or on statutory change). Inflation-adjusted constants — the FBAR threshold, Form 8938 thresholds, the §877A capital gain exclusion, the Puerto Rico Act 60 filing fees — update automatically at the quarterly cycle. Structural rule changes — a treaty amendment, a new revenue procedure, a Tax Court decision — trigger an out-of-cycle refresh with the change flagged prominently on the affected page.
Every page carries a snapshot date. Readers should not rely on a stale snapshot for a live filing decision.
This is a research and educational reference. It is not tax advice. The Baratelli Institute is a publisher under the Lowe v. SEC publisher exception, not a tax practitioner. Any reader whose facts turn on a specific filing decision should consult qualified international tax counsel. The reference exists so that when you have that conversation, you know what questions to ask.