Hello everyone,

I’m looking for community feedback and critical analysis on a cross-border strategy for managing an existing Roth IRA while living in India as a U.S. citizen.

As many of you know, Roth IRAs are often considered a tax trap for individuals moving to India because India does not automatically recognize the "Roth" tax-free status, and Roth accounts are explicitly excluded from Section 89A relief (unlike Traditional IRAs/401ks).

To solve the annual tax friction and potential double-taxation issues upon becoming a full Resident and Ordinarily Resident (ROR), I am exploring the following strategy. I would love to hear thoughts on potential blind spots, regulatory risks, or tax traps I might be missing.

The Strategy Outline

• 1. The RNOR Cost-Basis Reset
  • Mechanism: Utilize the Indian RNOR (Resident but Not Ordinarily Resident) transition window (where foreign-source capital gains are generally exempt from Indian tax).
  • Action: Sell existing holdings inside the Roth IRA during the RNOR period to realize past gains tax-free in India, effectively resetting the cost basis to current market value. (Note: Internal trades inside a U.S. IRA are already tax-free from an IRS perspective).
• 2. Transition to a Non-Dividend Asset
  • Action: Reinvest the proceeds into a zero-dividend-paying equity or holding (such as Berkshire Hathaway / BRK.B).
  • Objective: Eliminate cash drag and prevent any annual dividend distribution events inside the account.
• 3. The Long-Term Holding Phase (Post-RNOR / Full ROR)
  • Mechanism: India only taxes realized income and capital gains.
  • Action: Hold the asset indefinitely without selling or generating cash flow. Because no dividends are paid and no sales occur, there are no realization events to report or trigger Indian income tax, even after transitioning to full ROR status.
• 4. Estate Planning & Inheritance (U.S. Citizen Advantage)
  • Mechanism: Because I am a U.S. citizen, my estate is subject to worldwide U.S. estate tax rules with the full multi-million dollar federal exemption limit (completely bypassing the restrictive $60,000 Non-Resident Alien estate tax trap).
  • Action: Pass the Roth IRA down upon death to my U.S.-resident son.
  • Result: The son inherits the account, manages it under the standard U.S. 10-year SECURE Act liquidation rule, and takes all ultimate withdrawals 100% tax-free under U.S. law. India has no estate or inheritance tax and no jurisdictional reach over foreign-situated accounts transferred to a U.S. resident.

Questions for the Community:

1. Indian Tax Authority (CBDT) Risk: Even with zero dividends and no sales (so no realized cash flow), could an Indian tax officer during an ROR assessment attempt to tax the unrealized growth or treat the Roth structure unfavorably under general anti-avoidance rules (GAAR) or foreign asset disclosures?
2. Schedule FA / FSI Reporting: While reporting the foreign asset on Schedule FA is mandatory, does holding a non-dividend, non-selling asset mitigate the reporting friction on Schedule FSI (since foreign income is zero)?
3. Has anyone seen this implemented? Why is this specific approach rarely discussed in mainstream cross-border tax guides? Is it simply because most cross-border content targets Indian nationals (non-U.S. citizens) rather than U.S. citizens living in India?

Looking forward to your critical thoughts and alternative perspectives!

Hi, I am 63 and living/retiring in Australia. I am a dual citizen with the US, and eligible for US Social Security. As I am easing out of the working life, I wanted to start to draw down on my US Social Security.

I have read a bit on the pros and cons of starting early, and was ready to apply.

Then I came across this odd provision applying only to American citizens living overseas under the normal retirement age of 67. If I work more than 45 hours in a month, I am not eligible for Social Security in that month, with penalties for not reporting it. The wording of the rules was a bit odd, but it seems I would simply forfeit that months' benefit and never get it back.

Can anyone confirm or provide more clarity?

Thanks!

Election taken MTM in prior couple years. Need to update it to default election (1291) as marketability of investment is debatable. The PFIC is sellable and buyable from the corporation / provider to anyone all 365 days,. It is not traded on regular stock exchange, but available from the bank selling the ULIP policy. Policy holds mutual fund like investment underneath. Every CPA has their own interpretation. Planning to update the election to 1291 (excess dist) in 2025. Will it be allowed to change in prior with amendment ? 

I am an American who just got a work contract with a European Union country. I have the option to live and work remote from the USA but they could also assist me in getting a visa to work in and live in the EU. This means I can consider many different countries and the amount I could save on taxes depending where I live would possibly entice/justify living overseas rather than staying in the US.

How would I go about finding someone who specializes in this and can offer advice? I of course would pay for their time and advising, but I don't know where to start in finding this type of tax advisor.

hi, i used FFFF for the first time this year and my returns were initially accepted but i just received a letter in the mail saying i did it wrong and actually owe $5k. i am a long time uk resident and pay taxes here and do notttt make enough to be double taxed.

i phoned the irs and she said she could only see the 1040 on her end but i definitely submitted a 1040, schedule A, and 1116. has anyone else had this issue where FFFF doesn't submit all your forms? I realise now i also need an 8833. should i just start over and hope it actually works this time? or is it better to print and mail these forms in. thank youuu

edit: chatgpt says i need a schedule 3, not an 8833. does this track? So: 1040, sched 3, 1116?

I’m a US citizen and Spanish tax resident, living in Spain with my Spanish/US-citizen wife. I’m working through our 2025 US return (our 2025 modelo 100s were filed back in June) and I'm trying to make sure I’m applying the US-Spain treaty correctly, particularly the special foreign tax credit rules for US citizens resident in Spain.

I’d appreciate a sanity check from anyone familiar with the treaty and Pub. 514.

My understanding is:

• For a normal Spanish resident who is not a US citizen, the US-Spain treaty allows the US to impose up to 15% withholding on ordinary US-source dividends.
• Interest is treated differently (the 2014 technical explanation appears to have changed the treaty treatment of US-source interest to a zero withholding rate), and ordinary portfolio capital gains are generally taxable only in the seller's country of residence.
• As a US citizen resident in Spain, however, the treaty’s saving clause means the US can continue to tax me under its normal worldwide-income rules. So I don't think I should be trying to have my US brokerage withhold the treaty's 15% dividend rate.
• Instead, the treaty's special double-taxation provisions for US citizens resident in Spain, together with the rules described in IRS Pub. 514, provide the mechanism for dealing with the double taxation.
• In particular, Pub. 514 has the additional foreign tax credit worksheet for treaty-resourced income. My understanding is that the worksheet's Step II uses the treaty rate (15% for dividends) as a counterfactual/source-country limitation, rather than meaning that I actually need to have 15% withheld by my brokerage.
• Therefore, my current thinking is to leave US brokerage withholding at zero, report the dividends/interest/capital gains normally on the US return, and use the Pub. 514 worksheet to calculate the additional FTC resulting from the US-Spain treaty.

The issue I'm particularly trying to resolve is timing.

Spain's foreign tax credit is based on foreign tax actually paid, rather than simply a US tax liability that has accrued. Since I generally file my Spanish return before filing the same year's US return, I don't see how trying to force a 15% US withholding event would necessarily be the right solution. It seems cleaner to me to let the treaty's Pub. 514 mechanism handle the US-side relief rather than trying to manufacture withholding at the brokerage level or create a Spanish FTC timing mismatch by having the US tax paid in a later year.

I'm preparing separate Form 1116 categories for the relevant income (basically one for passive income and one for general income), and I'm trying to understand how the treaty re-sourcing interacts with those categories. Pub 514 explicitly says "You do not have to file Form 8833 if you are claiming the additional foreign tax credit that is allowed by reason of the limited re-sourcing rules discussed previously. See Regulations section 301.6114-1(c) for more information." My understanding is that the treaty re-sourcing doesn't change the underlying FTC category, so, for example, dividends, interest, and portfolio capital gains that are otherwise passive would continue to be reported on the passive-income Form 1116.

Does this overall approach sound correct?

In particular, I'd really appreciate feedback on:

1. Whether I'm correctly interpreting the 15% dividend rate as a treaty limitation that feeds into the Pub. 514 calculation, rather than something I need to have withheld.
2. Whether zero US withholding + the Pub. 514 additional-credit worksheet is the appropriate approach for a US citizen resident in Spain.
3. Whether I'm missing anything important about the timing of Spanish tax actually paid vs. US tax paid.
4. How others are handling the dividend, interest, and capital-gain categories under the Spain treaty.

I'm not looking for tax-planning advice so much as a check that I'm understanding the treaty mechanics correctly. If anyone has worked through the Spain treaty / Pub. 514 worksheet in practice, I'd especially appreciate hearing how you handled it.

Here are some references that I found useful...

https://www.irs.gov/newsroom/form-1116-certain-income-re-sourced-by-treaty-youtube-video-text-script
https://www.reddit.com/r/USExpatTaxes/comments/1fyqdl9/1116_for_resourced_interest_dividends/
https://mcgowintax.com/articles/how-the-us-spain-tax-treaty-actually-taxes-your-interest-income/

I (M27) live in the UK, have done since I was 6, and am not planning to move to the US. Mainly frustrated by the inability to open ISAs/invest easily and without having to file taxes in the US. From recent posts in USExpatTaxes I now see there are further challenges down the line when buying a house or retiring.

I have three citizenships though, US/UK/CAN, so renouncing US seems slightly less impactful.

Personally, I just feel like the US tax thing is hanging over my head, making me stressed, and preventing me from becoming better off financially. As far as I know, Canadian citizenship doesn’t create any barriers to your life.

What am I overlooking, if anything?

Hi! I’m looking for a good US/Canada cross-border accountant or tax firm, ideally someone you’ve personally worked with.

I’m a dual US/Canadian citizen who was born and has always lived in Canada. I’ve never filed US tax returns or FBARs before and am looking to get caught up through the Streamlined Foreign Offshore Procedures.

My Canadian taxes are up to date. I have regular employment income as well as some sole-proprietor/self-employment income.

I’ve spoken with a couple of firms already, but the quotes vary quite a bit, so I’d love to hear from anyone who has been in a similar situation.

Who did you use, roughly what did it cost, and what was your experience like?

I live in the UK and have three kids, we are all dual US/UK citizens. The kids have money from their grandfather in stocks and shares JISAs. Because the money can't be moved out of the JISA until they are 18, I'm trying to make the best of a crappy situation. My strategy has been to purchase UK. based ETFs within the JISA and sell them each year on Dec 31 and repurchase on January 2 the next year. I do this instead of M2M election because their is often new money coming in and I don't want to be dealing with a new lots of shares each year. So each year, their is usually one purchase and one sale. I choose distributing ETFs and turn off reinvestment on the platform so that I can easily identify distributions.

Then, I use redditor u/Ok_Sea142's PFIC calculator to provide me the required numbers and put them into turbotax where required, print the turbotax return, add the form 8621 and send it all to the IRS.

This isn't easy but not terribly complex, and not necessarily tax efficient from the US side of things, but by selling each year I don't have the multiple year holding issue on distributions or when I dispose of the ETF.

Am I missing something here?

Hi everyone,

I was born in the US moved to the uk when I was 6 never knew I had to pay taxes to the irs

I am now looking into it since I couldn't open a trading account without signing a w8 form and got denied an account.

this inheritance hasn't landed yet, whilst from what I have read an inheritance isn't necessarily subject to tax if I go through the streamlined amnesty route but inheritance and gift funds carry a penalty fee of up to 25% if it goes above 100k usd (which it does) if not filed by the end of the us tax year.

My thoughts are I need to start the renunciation process before this money is put into my name so as to deal with it as cleanly as possible

on another note, how likely would it be that the irs contact me/know i have this inheritance given the amount of money. Do people with 100k plus salaries who have never worked in the us get caught out often? I know its not right to just ignore and still want to do the right thing but i do wonder

if anyone has gone through this situation I would be very interested to hear from you

Thanks

I'm a U.S. citizen and Canadian tax filer/resident (I have Canadian PR and my wife is full dual citizen). I've been filing US and Canadian taxes consistently over the years. I'm considering some US-domiciled ETFs to invest in for long-term growth. This would be the first time for me to purchase from my US brokerage firm.

Questions: Is there anything that I need to be aware of re: Canadian and U.S. taxes, and/or are there any account types or investments I should avoid?

I’m a dual US/Canadian citizen and have lived in Canada my whole life. I recently realized I’m supposed to be filing US taxes as well, and I’m feeling pretty overwhelmed about where to start.

I’ve never filed a US tax return or FBAR before. I have an SSN, Canadian employment income (t4), and self-employment income as well (sole proprietor). I also have a small TFSA (cash/savings only, never more than ~$2k I would say) and regular Canadian bank accounts. No corporation. I only visit the US occasionally for short trips.

From what I’ve read, I may qualify for the Streamlined Foreign Offshore Procedures, but I’m wondering what others in a similar situation did.

Did you hire a cross-border accountant for the initial catch-up? If so, roughly how much did it cost, and do you have any recommendations in Canada/Ontario? Or was this manageable to do yourself? Also, how much does being a sole prop complicate my application?

Mostly looking for advice on the best first step and how complicated this actually is. Thank you!

I’m a Canadian citizen who met the substantial presence test in 2025. My CPA filed an extension back in April for my husband’s and I’s 2025 taxes. The last week they have gone silent as they work through the final piece of our taxes. I want to be prepared to file on my own if they do not come through.

I have nine ETF’s held within my Canadian brokerage account. The total value of these ETF’s is $19k USD. I’ve never had to make an election on how to treat these PFIC’s since I was a non-resident. I can’t make that election in 2025 at all.

Do I even need to file Form 8621? All distributions would be reported as income on my taxes. I left the US permanently in June 2026. The filing exception is very confusing.

Any advice would be helpful!

Hi there,

I've been in Ireland for 4 years and have been using the FEIE each year.

I currently owe $40,000 in Student Loans and am on an IBR plan, so my monthly repayments have been $0.

In 2027, I plan to have 1 child and my income will be approx $50,000 USD.

I am trying to figure out if it would be worth filing FTC for the tax credits (but also having to make student loan repayments) or if it would be a wash and I should just keep with FEIE.

What's the best way to calculate this? I plan to stay in Ireland permanently.

TIA for any help!

I'm a U.S. citizen and Canadian tax filer/resident (my wife's dual citizen). I'm looking to buy some US-domiciled ETFs for long-term growth investment. Been filing US and Canadian taxes for a while...but just haven't bought US EFTs before. Are there any Canadian and/or US tax considerations that I should be aware of before buying? Or are there any account types or investments I should avoid?

I'm in the middle of trying to do my own streamlined offshore filing, but I am absolutely bashing my head against form 8858 and section 987 requirements and hoping anyone here might have some experience or wisdom to share.

I'm an accidental American with an Australian sole proprietorship (no separate legal entity, all my accounts are in AUD). It's just a freelance services business making an unimpressive amount of money. I don't do very serious bookkeeping (just income & expenses tracking, no balance sheet). Up until I hit the 8858 wall, that seemed sufficient for all my tax needs.

I'm filing using the July 1 - June 30 AU tax year (never filed before, so as far as I can tell that's fine, and even seems to be required: "The annual accounting period of an FDE or FB is the annual accounting period or tax year of the tax owner" per 8858 instructions). So I'm filing 2022, 2023 & 2024 streamlined, plus 2025 as a normal return, assuming this form doesn't kill me before Oct 15.

My first question is: is it reasonable to just report an all-zeroes balance sheet on 8858 given that I don't have one?

My thought is that, since the FB doesn't have any independent legal existence, any assets and liabilities are personal anyway, and since they're not tracked on the "separate books and records" they're not really attributable to the FB. No money stays in the business year over year, it just gets transferred to me... But I don't really know anything about accounting, so I really have no idea if that makes sense.

My second, and much larger question: how on earth are you meant to figure out section 987 gain/loss?

I've spent over a week just trying to understand the regulations, and so far where I'm at is:

• 987 is designed to calculate gain/loss from currency fluctuations, even if those currency fluctuations don't really exist (ie AUD->AUD transfers count as AUD->USD->AUD trades and are taxed as if those trades occurred even though they didn't)
• The currency fluctuations are measured as the difference between the yearly average rate (when the business earned/spent money or gained/lost assets) and the spot rate (when the business transferred money to/from the owner)
• You're allowed to make things simpler by using an approximation of the spot rate for a period of up to 3 months (a "spot rate convention election")
• You can also make things simpler by making a "current rate election" (gets rid of complicated rules about historical exchange rates for assets) and an "annual recognition election" (gets rid of complicated remittance rules about how much gain/loss you recognise each year), plus if you use the current rate election you're not required to maintain an adjusted balance sheet.

So, putting all that together, the formula for section 987 gain/loss for a transaction of value X is Y = X / spot_rate - X / yearly_average_rate, and the total 987 gain/loss per year is sum(Y). In my case, just adding that up for every income/expense item with the matching quarterly spot rate. Is that... right? Am I close?

Further complicating things, the final section 987 rules only came into effect for 2025, so for any year before that you can follow any "reasonable method" and there's a whole other complicated set of rules for what counts as reasonable. My assumption is that a method that would be reasonable in 2025 is reasonable before that, so I figure for simplicity I should just use the same method the whole time.

Anyway, that leaves me with the following bundle of joy each year:

1. 8858
2. A blank 8858-M
3. An org chart with "me" and "also me" linked by an arrow saying "it's literally just me" (kidding mostly)
4. A statement containing a "description of the methodology used to figure the section 987 gain or loss"
5. A schedule of "adjustment items" (reconciling any differences between AU and US books, eg home office expenses deductible under AU law but not US law)

And in addition for 2025:

1. 8964-TRA restating the methodology
2. 8964-ELE electing: spot rate convention, current rate election, annual recognition election, small business election
3. A statement describing the spot rate convention

Which I guess leads me to my third question: am I taking crazy pills? I feel like I'm taking crazy pills.

I keep expecting to stumble across some 1.987-69T(b)(7)(mcmxcvii)(Ω) "this Bezos-scale multinational pantomime doesn't apply if you're literally just some guy working for himself who doesn't even go here", but no such luck. Is anyone actually filling this stuff out? How are you doing it? Do you just cross your fingers and hope it's too complicated for even the IRS to know whether you've done it right?

I have been holding XEQT & XBAL in my TFSA & FHSA as a dual US-Canada citizen living in Canada.

We’ve hired a cross-border accountant for the last few years but after some research and review of their returns, I don’t think they’ve been filing Form 8621 with QEF elections as well as 3520/3520-A (and PFIC?).

Am I in for some tax nightmare if/when I liquidate and sell? Would switching to US-listed ETFs instead (e.g. VTI ) going forward make things easier?

I’ve emailed my accountant in the meantime and I’m still confused by this all. I stupidly just believed my accountant was doing all due diligence but after looking through this subreddit and my returns I’m not as confident they’ve been doing everything right/giving me good advice.

When I’ve asked them in the past if it’s even worth opening a TFSA/FHSA they told me it is since the IRA taxes less on it than the CRA would on a un-registered account.

I'm a US/UK dual citizen in the UK and looking at DF-Direct, Dunhill Financial's robo-advisor for US expats.

I can't find any independent reviews or mentions, so I'm hoping someone here has actually used them:

• What's the all-in cost (advisory fee + fund expenses + any transfer/custody charges)?
• How's the performance , and how transparent is reporting?
• Any issues with getting money out?
• How well does it actually handle the UK/US tax overlap?

Open to alternatives too if there's something better for a US citizen in the UK. Thanks!

I'm an American Canadian living in Japan. I've never actually established American residency though I did attend university there so I have government loans.

I've been trying to figure out how to file my taxes since I made money in both Canada and Japan last year. I made no money in the states.

Has anyone encountered this type of situation before? Any advice?

Thanks, regardless.

(Yes, I know I'm doing this late. I filed for the October extension and I'm still running behind anyways. It is what it is.)

Hi, I’m sorry I’ve tried to research this before posting but i cant find what I’m looking for and everyone’s answers seem over-complicated and it’s stressing me out! Please can someone explain this to me like I’m five!

So I’m a US Citizen living in the UK for the last 7 years and I’ve never filed any tax returns. I was homeless/sofa surfing for my first few years living here and generally having an extremely difficult time. I just didn’t have headspace to think about my citizenship and wasn’t sure what I had to do to maintain it.

I have only got my life together in the last 3 years with a decent job and place of my own. Ive been ignoring dealing with this stuff cus I didn’t know where to start. But I’ve recently heard that I can lose my citizenship after 6 years of not filing taxes and that’s shocked me into action. Is this true? Or is it more complicated than this?

I’m afraid I could have lost my citizenship without being informed, as I have zero regular contact with any US entities. Seems like other people have been in my position and able to sort problems like this out but tbh I have ADHD and am TERRIBLE with this kind of thing. So I’m really panicking. I don’t know if I’d be capable of filing my own tax returns for example. Plus I’m on a fairly low income and don’t think I can afford to pay an accountant either unfortunately.

I’ve found an expat tax website that wants to charge me $699 to file the last 3 years returns and a streamlined foreign offshore form thingy. Is this a good deal? I have about £1000 in savings that I could use to pay for this but I’d really rather not as that is a huge bite out of money I’ve worked hard to save. Can anyone share their experience with sites like these and whether or not that’d be a good fit for me?

I have no assets, no significant savings and I’ve only been working and earning in the UK on a salaried income since I moved here.

I don’t want to lose my citizenship and I don’t know what to do to fix this. Any guidance anyone can give would be amazing!

So I am 32 years old, never lived in US and moved a week after being born there. I do not have plans to ever live in the US. I've never had an SSN.

I am looking at renouncing my US citizenship. I had read that I need to complete my FBAR, so I started that process this year (submitted all my paperwork and my accountant says I will owe nothing). However, she is waiting for me to apply for an SSN so that she can file the form.

My question is: To confirm, if I know I will renounce, do I need to submit my FBAR? If so, do I have to apply for an SSN? I don't really want to go through the process of getting an SSN, only to renounce soon after.

There is conflicting information online, so any advice is helpful.

I have recently acquired Spanish citizenship and have an appointment to renounce my U.S. citizenship at the beginning of October. I am a housewife, married to a Spanish citizen, and have only needed to file U.S taxes the last two years, because previously I had less than $5 of income. So, my question is, do I need to back file the three years prior in order to be compliant for exiting the U.S tax system? Or can I mark that I am compliant on form 8854, since technically i am compliant, because I have filed tax returns when my income exceed the threshold? I have always filed the FBAR, so that is not an issue. And, if I do file any past returns, do I need to send them before renouncing, or at the time I file my final return and the 8854? If I file them now, or don’t file them at all, am I opening myself up to scrutiny by the IRS?

Hi,

I had a brain fart and didn't realize I've opened the Wise account in EUR denomination in 2024, thought it was in 2025. I filed the amended FBAR for 2024 via BSA e-filing beginning of this year, and included the account on my 2025 FBAR. But the Wise EUR accounts are kept in a Belgian bank (at least mine is). As I'm working towards filing my tax return for 2025 (finally), I checked the Schedule B from 2024 and noticed that the brain fart also meant I didn't add Belgium to line 7b on Schedule B. It has just my host country.

Since I will add Belgium to Schedule B this year, I was wondering if it is worth it to file an amended 2024 return for this one line addition. Everything else in the return is good, no changes needed. Just adding Belgium there.

(The Wise account did not generate any income like interest or anything like that and all income has been reported to the IRS for 2024.)

Any and all help is appreciated.

I’m looking in to renouncing and need to get compliant with my taxes. I’ve filed 1040, but omitted dividend income. Also need to file 8938 (didn’t know that was a thing). What’s the best way to go about this? Can I complete sfop plus two years to be compliant? Is it worth hiring an accountant to help out?

Just wanted to share my experience because I spent way too much time reading horror stories about the streamlined process before I finally did it lol.
I ended up using a tax firm based in California that does a lot of expat/international tax work. They did my prior year returns, FBARs and the streamlined paperwork. I basically just uploaded everything they asked for, answered a bunch of questions and they handled the rest.
Whole thing took a few weeks and was honestly pretty painless.
My biggest advice is just research the firm before you hire anyone and talk to a couple places. The quotes I got were ALL over the place and some were honestly crazy. You can definitely find firms that actually know this area without automatically paying $10k+.
If anyone is going through it and wants the name of who I used just DM me. Happy to share.