The Baratelli Institute · International Tax Reference

US Persons Living Abroad — The Practitioner Reference

A single-page overview for US citizens, green-card holders, and long-term US permanent residents living outside the United States. Foreign account reporting (FBAR / FATCA), foreign earned income exclusion (§911), foreign tax credit (§901), controlled foreign corporation rules (GILTI / Subpart F), Passive Foreign Investment Company (PFIC) exposure, treaty tie-breaker mechanics, Streamlined Filing Compliance Procedures for taxpayers correcting historical gaps, and the §877A exit tax for those considering formal expatriation. Every topic links to a full reference walk-through.

Snapshot: 2026-07-03 · Audience: US citizens, green-card holders, and long-term LPRs residing outside the United States · Applied companion: The International Tax & Cross-Border Wealth guide

The universal framework

Every US person abroad reads this first

The United States is one of only two countries in the world — Eritrea is the other — that taxes its citizens on worldwide income by citizenship, not by residence. Every other developed country taxes only its residents. That single difference is the source of almost every complication an American abroad will face for the rest of their life.

The practical consequence is unambiguous. Every US citizen, every US green-card holder, and every long-term US permanent resident must file a US federal income tax return every year, reporting worldwide income, regardless of where they physically live, whether they earn a single dollar of US-source income, or whether they have set foot on US soil in a decade. The obligation runs with the passport (or the green card), not with the residence. A US citizen living in Berlin for thirty years and earning entirely in euros still owes an annual Form 1040 to the IRS.

This obligation is separate from — and additional to — whatever the host country requires. A US citizen resident in Germany files a German tax return under German law and a US federal return under US law. The two systems talk to each other through a bilateral income tax treaty and through the mechanics of the foreign tax credit (§901) and the foreign earned income exclusion (§911), which together prevent the same dollar from being taxed twice at the combined economic rate. But the two filings are legally independent. Even in years where the treaty and the credit mechanics reduce the US bill to zero, the return itself is still required.

The tax treaty tie-breaker rules for residency exist to allocate sourcing rights between two countries that both consider a taxpayer resident under their internal rules. They do not, and cannot, eliminate the US filing obligation of a US citizen. This confuses many people every year and is the single largest driver of the historical noncompliance that the IRS's Streamlined Filing Compliance Procedures were designed to fix. If you have never filed a US return while living abroad and just discovered you were supposed to, the Streamlined program is almost certainly the path forward. Section 4 of this page walks it.

The seven topics every US person abroad has to understand

The seven-topic framework — with links to full walks

The specialist cross-border practitioner conversation for an individual US person abroad reduces reliably to seven topics. Some apply to almost everyone (FBAR, FEIE or FTC). Some apply to a subset with specific facts (GILTI for CFC owners, PFIC for anyone with local mutual funds, §877A for the departing). Each card below opens the full walkthrough where one exists in the Baratelli Institute reference set.

1. Foreign Earned Income Exclusion (§911)
Up to $133,700 (2026, indexed under §911(b)(2)(D)) of foreign-source earned income excluded from US taxable income if the physical-presence test (330 days abroad in any 12-month window) or the bona fide residence test is met. Housing exclusion stacks on top. The §911 election is the default answer for the salaried expat with modest foreign-employer wages.
Read the applied treatment in the paid guide →
2. Foreign Tax Credit (§901)
Dollar-for-dollar US credit for foreign income tax paid, up to the US tax on the same foreign-source income. The alternative to §911 exclusion and often the better answer for taxpayers in high-tax jurisdictions (Germany, UK, France) whose foreign tax already exceeds what US tax would have been. Passive- and general-category baskets are computed separately.
Read the applied treatment in the paid guide →
3. FBAR (FinCEN 114) and Form 8938 (FATCA)
Foreign account and asset reporting. Two different forms, two different agencies (FinCEN and IRS), two different thresholds, and two different penalty regimes. Most US persons abroad file both. The full decision matrix is one click away.
Open the Form 8938 vs FBAR reference →
4. GILTI, Subpart F, CFC rules
For US individual owners of foreign operating businesses. The 2017 TCJA reshaped the calculus for any American abroad who owns 10% or more of a non-US corporation. The Grand Rapids Aerospace worked case walks the same $4,000,000 of Irish profit through a C-corp owner, an individual owner (the “GILTI trap”), and an individual owner making the §962 election.
Open the GILTI walkthrough →
5. PFIC rules (§1291 / §1295 QEF / §1296 MTM)
Foreign mutual funds, ETFs, unit trusts, and pooled investment vehicles are almost always PFICs when held by US persons, and PFIC taxation without a QEF or mark-to-market election is genuinely punitive — the highest ordinary rate plus an interest charge on deferred gain. The Sarah / UK OEIC worked case walks the default, QEF, and MTM outcomes side by side.
Open the PFIC walkthrough →
6. Treaty tie-breakers & totalization agreements
How bilateral income tax treaties allocate taxing rights between two countries that both claim a taxpayer as resident, and how bilateral totalization agreements coordinate Social Security so a worker doesn't pay both US FICA and the host country's payroll tax on the same wage. The Country Comparison Matrix walks the top-10 partner treaties.
Open the Country Comparison Matrix →
7. §877A Expatriation Exit Tax
For US citizens and long-term green-card holders who are considering formal renunciation of citizenship or surrender of the green card. The exit tax deems all worldwide assets sold at fair market value on the day before expatriation. Eduardo Saverin's departure is the worked case.
Open the §877A walkthrough →
The PFIC trap for Americans buying local mutual funds. US persons abroad who buy local mutual funds through their host-country brokerage account are almost always buying PFICs. A German-domiciled UCITS ETF is a PFIC. An Indian equity mutual fund is a PFIC. A UK-listed OEIC is a PFIC. Without a QEF election (rarely available because non-US funds do not report in the US-tax-compliant format the QEF election requires) or a mark-to-market election (available only if the shares meet the §1296 marketability test), the default §1291 regime applies excess-distribution rules that tax the gain at the highest ordinary rate plus an interest charge on the deferral. The right answer for most US persons abroad is to hold US-domiciled ETFs (VTI, VXUS, etc.) in a US brokerage account — the equivalent host-country product will save 0.05% in expense ratio and cost multiples of that in US tax friction.
The single most important compliance path

Streamlined Filing Compliance Procedures — the fix for the taxpayer who just discovered the obligation

The Streamlined Filing Compliance Procedures are the IRS program for US taxpayers who failed to report foreign income or file the required foreign-asset returns and whose failure was not willful. The program was launched in 2012 and expanded in 2014. It has since become the standard remedy for the very large population of US persons abroad who simply did not know they were supposed to file a US return while living outside the country.

The program has two variants. Which one applies turns entirely on where the taxpayer physically lives.

Feature Streamlined Foreign Offshore Procedures (SFOP) Streamlined Domestic Offshore Procedures (SDOP)
Who qualifies US taxpayer who meets the non-residency requirement (physically outside the US for 330+ days in one of the three tax years covered) US taxpayer resident in the United States who fails the SFOP non-residency test
Willfulness certification required? Yes — Form 14653 non-willful certification Yes — Form 14654 non-willful certification
Amended returns required 3 years of amended Form 1040s 3 years of amended Form 1040s
FBAR (FinCEN 114) returns required 6 years of delinquent FBARs 6 years of delinquent FBARs
Miscellaneous offshore penalty 0% — no penalty 5% of the highest aggregate balance of the covered foreign financial assets over the covered period
Late-filing / accuracy penalties on the amended returns Waived Waived
Interest on the tax owed Payable Payable
The practical rule The right program for the American abroad who discovers the gap while still living abroad The right program for the American at home whose foreign accounts predate the discovery
Why the SFOP zero-penalty result matters. Congress and the IRS built the Streamlined program to correct a specific historical problem: an entire generation of US persons abroad who genuinely did not know a US filing obligation followed them across the border. For that population, the SFOP delivers full compliance restoration with no cash penalty — three years of returns, six years of FBARs, and interest on any actual tax owed, and the record is clean. For a taxpayer who still lives in the US and has the same historical gap, the SDOP costs 5% of the peak account balance, which on a mature retirement or investment account is real money. The 330-day non-residency test is the line, and it is drawn strictly.

Willfulness is the whole game. If the IRS determines that the failure to file was willful — that the taxpayer knew of the obligation and deliberately did not comply — neither Streamlined variant is available. The taxpayer is instead exposed to the Foreign Bank Account Report civil willful penalty, which under 31 U.S.C. §5321(a)(5)(C) is the greater of $100,000 or 50% of the account balance per violation year, and to potential criminal exposure. The non-willful FBAR penalty, by contrast, is capped at $10,000 per unfiled Form 114 and applies on a per-form (not per-account) basis, as clarified by the Supreme Court in United States v. Bittner, 598 U.S. 85 (2023). The non-willful certification signed under penalties of perjury is not a form; it is a document that has to be defensible on the merits, and a qualified practitioner is essential.

For the applied framework: the Institute's International Tax & Cross-Border Wealth guide (Vol XII) Chapter 5 walks the practitioner-grade Streamlined engagement end to end — the willfulness analysis, the return prep sequence, the accompanying certification narrative, and the post-submission monitoring.

Country-specific considerations — the top 10 partner countries

Where the US person abroad most often lives — and the local complication that matters

The list below is not exhaustive. It reflects the countries where the Baratelli Institute sees the highest recurring practitioner-question volume from US persons abroad, weighted by both population and complexity per taxpayer. Every row assumes the taxpayer is a US citizen or green-card holder resident in the country listed.

Country US income tax treaty in force? Signature complication Institute reference
United Kingdom Yes — 2001 US-UK treaty (with 2002 & 2003 protocols) Savings clause preserves US taxing rights on citizens; ISAs are not US-tax-recognised wrappers; UK pension treatment is treaty-favorable but requires care Country Comparison Matrix
Germany Yes — 1989 US-Germany treaty (with 2006 protocol) US-Germany totalization agreement handles Social Security allocation; German solidarity surcharge and church tax are creditable; Riester and Rurup pension products need PFIC-adjacent analysis Country Comparison Matrix
India Yes — 1989 US-India treaty Indian mutual funds are PFICs for US owners; NRE / NRO / FCNR accounts are all reportable on FBAR and generally on Form 8938; Indian PPF and EPF need specific treatment Form 8938 vs FBAR reference
Canada Yes — 1980 US-Canada treaty (with five protocols) RRSP is treaty-favorable but Form 8891 was retired — RRSPs still require FBAR; TFSAs are not treaty-recognised and are foreign trusts for US purposes; RESP treatment is punitive Country Comparison Matrix
Portugal Yes — 1994 US-Portugal treaty Post-NHR-reform regime (2024): the old Non-Habitual Resident 10-year window is closed to new entrants; the IFICI successor targets qualifying professionals; treaty planning has shifted Country Comparison Matrix
Ireland Yes — 1997 US-Ireland treaty 12.5% corporate rate makes any US-owned Irish CFC fail the §954(b)(4) high-tax exclusion threshold; GILTI hits at the shareholder level absent §962 election GILTI walkthrough
Netherlands Yes — 1992 US-Netherlands treaty (with 2004 protocol) 30% ruling is a Dutch payroll benefit, not a US-tax benefit — US filer still reports the full salary; Dutch box-3 wealth tax is not creditable against US tax Country Comparison Matrix
Switzerland Yes — 1996 US-Switzerland treaty (with 2019 protocol) Lump-sum (forfait) taxation is a Swiss cantonal-level regime; the US taxpayer still pays full US tax on worldwide income; pillar-2 and pillar-3 pensions need treaty analysis Country Comparison Matrix
Australia Yes — 1982 US-Australia treaty (with 2003 protocol) Superannuation is not treaty-recognised as a US-qualified pension — the analysis is unsettled; industry-standard positions treat contributions and earnings as currently taxable to the US owner Country Comparison Matrix
Singapore No — no US-Singapore income tax treaty in force Singapore taxes territorially at 0% on foreign-source and capital gains; without a treaty, no treaty-based benefits are available, but the §901 foreign tax credit for Singapore tax paid is still available on a per-basket basis Country Comparison Matrix

The full country-by-country walk is in the Baratelli Country Comparison Matrix. The Foundations PDF library also carries a printable country-comparison reference at the Foundations page.

When to hire local counsel

A practitioner note on what this page is — and what it is not

This page is a reference for orientation. It is not tax advice, and it cannot be tax advice, because tax advice requires facts. Every consequential decision in the cross-border tax stack turns on facts that a landing page cannot know: the taxpayer's specific residency history, the composition of the foreign account and asset base, the entity structure of any foreign business interest, the interaction with treaty positions taken in prior years, and the willfulness posture of any historical noncompliance. A US person abroad making any of the following decisions needs qualified counsel in both jurisdictions — not just a US CPA:

Practitioner selection matters. A CPA who handles domestic returns competently is not necessarily equipped for a CFC-owner return or a PFIC-heavy portfolio. Look for a firm that identifies as international-tax-specialist, holds credentials in both jurisdictions where possible, and prices the engagement in a way that reflects the actual complexity of the work. Cheap cross-border returns are almost always wrong cross-border returns.

The applied paid guide

The 236-page practitioner reference underneath this landing page

Cross-references

Companion reads

GILTI Walkthrough
The full §951A calculation with the Grand Rapids Aerospace worked case — C-corp owner, individual owner, §962-electing individual owner.
Open the reference →
Form 8938 vs FBAR
The decision matrix for which foreign-asset reporting form applies, when both apply, and how the two penalty regimes differ.
Open the reference →
§877A Expatriation Tax
The exit tax mechanics, the covered-expatriate tests, and the Eduardo Saverin case worked line by line.
Open the reference →
Puerto Rico Act 60
The Individual Investor Decree, the §933 exclusion mechanics, and the bona fide residency tests.
Open the reference →
Country Comparison Matrix
The top-10 partner treaties compared side by side, with the signature complication of each jurisdiction.
Open the reference →
Foundations PDF Library
The full Foundations catalog — free educational references, printable, cross-linked to the paid volumes.
Open the library →
International Tax Reference Hub
The top-level index for every cross-border walkthrough in the Institute reference set.
Open the hub →
The Paid International Tax Guide
Volume XII — the 236-page practitioner-grade reference underneath this free landing page. $349.
Open the product page →
Primary sources

Statutory, regulatory, and case-law citations

Every statute, regulation, court decision, and IRS publication cited or relied on in the body above. Verified against the current IRC and Treasury regulations at the snapshot date.

  1. IRC §61 — Gross income defined; the statutory basis for the worldwide-income rule that applies to every US citizen and resident regardless of physical location.
  2. IRC §901 — Foreign tax credit; dollar-for-dollar US cr