International & Expat strategies
10 plays in this category. Each one covers the mechanics, who it fits, and the estimated impact — then generates a deep dive against your own numbers.
- International & Expat
Foreign Earned Income Exclusion (§911 — $130K+/yr)
Exclude ~$130K/yr of foreign-earned income + housing exclusion — bona fide resident or 330-day test.
$30K–$70K/yr federal tax elimination - International & Expat
Foreign Tax Credit (§901) for High-Tax-Country Expats
Dollar-for-dollar credit for foreign income taxes paid — no cap, no phase-out.
100% credit for foreign tax paid = potential $0 US tax - International & Expat
§962 Election on GILTI Income (Corporate Rates)
US shareholder of CFC elects corporate rates + FTC on GILTI, cutting rate from 37% to ~21%.
Cut effective GILTI rate from 37% to 0–10.5% - International & Expat
Territorial Residency (UAE, Panama, Portugal NHR)
Establish residency in a 0-tax or territorial-tax country to escape US state tax + optimize CFC.
Eliminate 5–13% state tax + optimize CFC/GILTI structuring - International & Expat
US Mortgage for Expats & Non-Resident Investors
HSBC Expat, America Mortgages, Waltz, MBanc — 30-yr fixed US real estate loans for non-residents.
Access to US leverage otherwise unavailable to non-residents - International & Expat
Cook Islands / Nevis Asset Protection Trust
Non-US jurisdictions with no recognition of foreign judgments — bulletproof asset protection.
Asset protection with no direct tax cost - International & Expat
US Tax Treaty Tie-Breaker for Dual Residents
Claim treaty position to be taxed as resident of only ONE country, halving your compliance.
Halved compliance + treaty rate reductions on cross-border income - International & Expat
US LLC for Non-Residents (Wyoming/Delaware, $0 Fed Tax)
Non-resident aliens can own a US LLC, do US business, and pay $0 US tax if properly structured.
0% US federal tax on non-ECI income - International & Expat
Golden Visa / CBI Passport Diversification
Second passport / residency via investment (Portugal, Malta, Greece, Caribbean, UAE, Panama).
Optionality worth 5–15% of a diversified portfolio's risk-adjusted return - International & Expat
US Expatriation & Covered-Expatriate Exit Tax Planning
Renounce US citizenship — but plan to minimize the §877A mark-to-market exit tax first.
Millions in future US tax obligations eliminated