U.S. Tax in Mexico: Expat Filing, Treaty Planning, and Mexican Investment in the U.S.
U.S. tax guide for Americans living in Mexico and Mexican residents investing in the U.S., including treaty issues, Mexican entities, U.S. LLCs, and U.S. real estate.
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Form 8833: Treaty-Based Return Positions and When You Must Disclose Them
Claiming a tax treaty benefit that overrides U.S. tax law often requires disclosure on Form 8833. Here's when the form is required, when it's waived, and why the treaty tie-breaker can be dangerous for green card holders.
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GILTI and Net CFC Tested Income: How the U.S. Taxes CFC Profits
GILTI was renamed net CFC tested income for 2026, with a 40% deduction and a 90% foreign tax credit. Here is how the regime works for corporations and individuals, and how the Section 962 election and high-tax exclusion change the answer.
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PFIC Tax Rules: What U.S. Investors Need to Know About Foreign Funds
U.S. persons who own shares in foreign mutual funds, ETFs, or pooled investment vehicles are likely holding a PFIC. The tax consequences are severe by default, but elections are available that can change the outcome significantly.
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