How does the shift from GILTI to NCTI under the OBBBA affect me?

The OBBBA rebrands GILTI to NCTI and eliminates the 10% QBAI deduction. We utilize Section 250 deductions to maintain lower effective rates.

International Tax CPA | 2026 OBBBA & Real Estate Strategy

Q: Do I have to pay U.S. taxes on money I earn abroad?

Yes. The U.S. taxes worldwide income. We use FEIE and Foreign Tax Credits to eliminate double taxation.

Q: What is the difference between FATCA and FBAR?

FBAR is for accounts over $10,000; FATCA is for broader assets over $50,000. Both require meticulous 2026 compliance.

Q: What triggers a FIRPTA withholding requirement?

A 15% withholding on U.S. real estate sales by foreign persons. We apply for Withholding Certificates to reduce this to actual tax liability.

Q: How does the G7 'Side-by-Side' agreement affect OECD Pillar 2?

The G7 Side-by-Side arrangement protects U.S. companies paying the 12.6% NCTI rate from foreign 'top-up' taxes (UTPR).

International Tax & Cross-Border Consulting

Serving expatriates, foreign investors, and multinational businesses with FIRPTA, FATCA, and cross-border compliance.

Executive desk showing global financial data and city skyline, symbolizing cross-border tax strategy for international businesses and U.S. private clients.

Cross-Border Tax Solutions for Businesses & Private Clients

Managing global assets demands strategic planning. We provide specialized tax advisory for multinational businesses—including E-commerce, Oil & Gas, and Legal Services—as well as tech founders, foreign investors (FIRPTA), and private clients. From optimizing partner compensation for international law firms to navigating complex treaties, our Austin-based team ensures your cross-border operations are tax-efficient and compliant.

Compliance & Planning Standards

U.S. Taxation of Worldwide Income As a U.S. citizen or resident, you are generally taxed on your global income, not just what you earn in the U.S. However, we utilize Foreign Tax Credits (FTC) and the Foreign Earned Income Exclusion (FEIE) to prevent double taxation. Our goal is to apply the relevant treaties to minimize your liability while keeping you fully compliant.

FIRPTA (Foreign Real Estate Investors) The Foreign Investment in Real Property Tax Act (FIRPTA) mandates a withholding tax of up to 15% when a foreign person sells U.S. real estate. We assist with withholding certificates (Form 8288-B) to reduce this amount upfront and handle the final tax return to help you reclaim over-withheld funds.

FATCA & FBAR Compliance The Foreign Account Tax Compliance Act (FATCA) requires strict reporting of foreign financial assets. Failure to file Form 8938 or the FBAR (FinCEN Form 114) can result in severe penalties. We manage these complex disclosures to ensure your international portfolio is reported correctly.

Streamlined Filing (Amnesty) If you are behind on your U.S. tax obligations, you may qualify for the Streamlined Filing Compliance Procedures. We help non-compliant taxpayers catch up on past returns penalty-free (in many cases) without fear of criminal prosecution.

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Cross-Border Tax Roadmap

Step 01

Residency & Nexus

We determine your tax home using the "Substantial Presence Test" and treaty tie-breaker rules to establish exactly where you owe tax first.

Step 02

Credit Optimization

We apply Foreign Tax Credits (FTC) and the Foreign Earned Income Exclusion (FEIE) to neutralize double taxation on your global income.

Step 03

Global Compliance

We execute your filings (FBAR, FATCA, Form 5471) with precision, ensuring full transparency to avoid costly IRS penalties.

Common Cross-Border Scenarios

I own rental property outside the U.S.

You must report rental income on your U.S. return (Schedule E), but you can typically depreciate the foreign property (over 30 or 40 years) and claim a Foreign Tax Credit for taxes paid to the local government.

I have a foreign pension (Superannuation / SIPP)

Foreign pensions are not automatically treated like a 401(k). Depending on the specific treaty (e.g., UK-US), growth may be tax-deferred, or it may be taxable immediately. We analyze your specific fund structure for compliance.

I received a large gift from a non-U.S. person

If you receive gifts or bequests totaling more than $100,000 from a foreign person, you must file Form 3520. No tax is due, but the penalty for failing to file can be 25% of the gift value.

Foundational Compliance for Global Taxpayers

Do I have to pay U.S. taxes on money I earn abroad?

Generally, yes. The U.S. taxes based on citizenship, not residency. This means your worldwide income is subject to taxation. However, we utilize tools like the Foreign Earned Income Exclusion (FEIE) and Foreign Tax Credits to reduce or eliminate double taxation so you don't pay twice on the same dollar.

What is the difference between FATCA and FBAR?

While both deal with foreign assets, they are filed differently. FBAR (FinCEN Form 114) is required if you have over $10,000 in foreign accounts at any time. FATCA (Form 8938) is filed with your tax return and has higher thresholds. We review your portfolio to ensure both are filed correctly to avoid severe non-willful penalties.

What triggers a FIRPTA withholding requirement?

FIRPTA applies when a foreign person sells a U.S. real estate interest. The buyer is typically required to withhold 15% of the gross sales price. We help sellers apply for a Withholding Certificate (Form 8288-B) to reduce this amount based on your actual tax liability rather than the gross sales price.

2026 Strategic Advisory & OBBBA Updates

How does the transition from GILTI to NCTI affect my CFC? +

Effective January 1, 2026, the OBBBA rebranded GILTI as Net CFC Tested Income (NCTI). The new rules eliminate the 10% QBAI deduction, meaning capital-intensive foreign businesses may see higher tax exposure. We focus on utilizing the new 40% Section 250 deduction to maintain an effective rate of 12.6%.

Can I still use Foreign Tax Credits to offset my 2026 NCTI liability? +

Yes. A major benefit of the 2026 updates is the increase in the deemed-paid foreign tax credit (FTC) allowance from 80% to 90%. This reduction in the "FTC haircut" is a significant win for U.S. shareholders, and we help model distributions to maximize this credit.

What is the new FDDEI deduction for export-driven services? +

The former FDII is now FDDEI (Foreign-Derived Deduction Eligible Income). For 2026, the effective tax rate for U.S. companies serving foreign markets is approximately 14%. We help service-based firms (tech and consulting) structure contracts to qualify for this preferential rate.

How does the G7 "Side-by-Side" agreement affect OECD Pillar 2? +

Under the 2026 framework, a "Side-by-Side" arrangement with the G7 ensures that U.S. companies paying the 12.6% NCTI rate are generally protected from foreign "top-up" taxes (UTPR). We provide the documentation required to prove U.S. compliance to foreign tax authorities.

Ready to Secure Your Global Assets?

Don't let cross-border complexity erode your wealth. Schedule a strategic consultation to align your international portfolio with U.S. tax law.

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