When Life Crosses a Border, So Do Your Tax Obligations

When Life Crosses a Border, So Do Your Tax Obligations

Jennifer: Let’s start with the basics. Who are you? 

Francheska: I’m Francheska Pimentel, a CPA and the founder of Pimentel LLC, where I specialize in international tax. I help individuals work through cross-border tax issues, whether they’re living or working overseas, have assets outside the U.S., or aren’t U.S. persons and are looking to move here or invest here. I also work with employers who are sending employees abroad or bringing someone from another country to fill a role in the U.S. 

Jennifer: If you looked at the overall makeup of your clients, is it mostly U.S. to U.K./ Canada, or is it a wider variety? 

Francheska: I’m really country agnostic. There are a few countries I see less often, but my work does lean toward Europe, since that’s where a lot of the movement to and from the U.S. happens. And lately, I’ve been seeing a lot of Canada. 

Jennifer: Interesting. That’s almost contrary to what you’d expect given where things stand between our countries right now. 

Francheska:  It’s true that things are a bit complicated right now. Many of the Canadians I work with tend to settle in the northern U.S., close to the border. They tell me it makes it easier to get back home when they want to, and many find jobs near the border rather than moving farther south. 

Jennifer: U.S. tax alone is incredibly convoluted. Every state is different, nexus is its own world, and now you’re adding an entire layer of other complications on top of that. How do you maintain subject matter expertise across so many different countries? If someone comes to you from a country you haven’t worked with before, what does that look like? 

Francheska: It really is a team effort. You need someone on the ground who’s an expert in that country, the same way I am on the U.S. side, and the two of us work together to make sure the client isn’t taxed twice on the same income. Sometimes that local expert isn’t even an accountant. In some countries, that role falls more to an attorney. So the key is finding the right person locally who can answer those questions. Then I work through how the U.S. will view the client’s situation, walk the local advisor through it, and together we land on an approach that works for the client in both countries. 

Jennifer: Do you have a network of international CPAs and advisors you tap into? 

Francheska: Yes. Over the years you cultivate relationships with people you’ve worked with and vetted, so you become comfortable saying, here’s someone who’s definitely an expert in this area. If I don’t already know someone in a given country, I reach out to peers who do similar work and ask for a referral. Some of my best contacts have come that way. 

Jennifer: We’ve had a similar experience working with clients who do business in different countries. We’re learning as we go in a lot of cases. We have a client that does business in parts of Africa, and it’s very difficult to make payments there. All the traditional international payment methods don’t work. The default ends up being Western Union, which was a fascinating learning experience for us. Old school but it works. 

What’s been one of the most surprising or unusual things you’ve encountered working across different countries? 

Francheska: One that comes to mind is clients with Venezuelan connections. They looked very wealthy on paper, but when their assets were frozen, they still had U.S. tax due on those companies and no access to cash to pay it. That’s an incredibly hard spot to be in. 

Jennifer: WOW! For us it was when a client made a payment to someone in Cuba that got seized. They never got it back and were genuinely shocked. I was a little less shocked. 

Are there countries you would generally advise clients against doing business in because of the constraints or difficulties involved? 

Francheska: Yes. The U.S. maintains a list of countries, generally ones it doesn’t have good relations with, where you can’t claim a foreign tax credit for taxes you pay there. So you could end up paying tax in that country and again in the U.S. on the same income. The list changes over time as countries are added or removed. You can still do business in those countries, but you lose a key protection against double taxation. If someone has personal or family ties there, sometimes there’s no way around it. But from a business perspective, I always make sure clients understand those limitations before they go in. 

Jennifer: I’d imagine that having a proactive conversation with you before making any of these decisions is always going to be more helpful than coming to you after. 

Francheska: Always. Whether someone is leaving the U.S. or moving here, planning ahead makes a huge difference. Retirement accounts that are tax-deferred in the U.S. may not be respected abroad, and someone moving to the U.S. may own foreign funds that become PFICs once they arrive. It’s far easier to plan around those issues before the move than to fix them afterward. 

Jennifer: What is a PFIC? 

Francheska: It stands for passive foreign investment company, but the easiest way to think about it is a mutual fund or ETF you bought in your home country, outside the U.S. The U.S. doesn’t like these because they let people put off paying U.S. tax on their investment growth, so it taxes them very harshly. That’s why, before someone moves here, we might talk about selling those investments first. But if someone is only coming for two or three years and plans to go back, it may make more sense to hold onto them and just handle the reporting while they’re here. 

Jennifer: When you think about pre-COVID versus post-COVID, it feels like more and more companies we work with now have employees all over the world. It used to be a big deal if someone moved from New York to New Jersey. Now people are going to Medellin for six months to work remotely. Are you seeing that shift? 

Francheska: Definitely. Before COVID, I saw a lot more long-term assignments, usually a year or more, where companies were sending employees overseas or bringing them to the U.S. Since COVID, companies have realized people can work from anywhere, so I’m seeing more short-term assignments instead. Cost plays a big part too. Sending someone abroad long-term is much more expensive for an employer than a short stint. 

What I’m also seeing more of is employees quietly moving overseas without telling their employer. I had a case just a couple of months ago where an employee had been working from Spain, and suddenly needed a letter from the company to give to the Spanish tax authorities. The employer had no idea he was even there. That creates real exposure for the company, because once someone is working in another country, the employer can have tax and payroll obligations there that it never planned for. 

Jennifer: We’ve had employees move states and even that process is significant. There are registrations, filings, fees, and it takes time. I always tell my staff, if you’re even thinking about it, let me know early. I can’t imagine managing that on an international scale. 

Francheska: And it’s not only employers sending people abroad. A lot of my clients come to me directly. They decided to make a move, maybe they fell in love with someone overseas or found a job there, and they’ve built a whole new life in Spain, Mexico, or Singapore. It’s fascinating to see what drives people, and since COVID, I’m definitely seeing more of it. Some are still working for a U.S. employer that knows they’ve moved. Others have been hired locally and are handling the immigration and tax side completely on their own. 

Jennifer: Speaking of going out on your own, you recently started your own firm. Why, and what has surprised you most since making the jump? 

Francheska: I’ve always wanted my own firm. I actually made business cards when I graduated college. I found a stack of them recently and had to laugh, because they look so dated now, but back then I thought they were fantastic. 

At my previous firm, I got very comfortable. I loved the team and the variety of work, so I kept putting it off. Then I went through a leadership development program, and the person running it asked me point blank what I really wanted. That got the wheels turning. Eventually I reached a point where I had to decide: commit to staying there long-term, or take the leap into the unknown. 

It was a risk, especially with a family. But one day I just said, I’m doing it. If it doesn’t work out, at least I won’t spend the rest of my life wondering what if. My partner is also self-employed, so we were in it together. 

Jennifer: I know that conversation well. 

Francheska: And honestly, it’s been the best decision I’ve ever made for myself. I don’t regret it at all. It’s pushed me to grow in ways I never expected. You wear so many hats: IT, business development, billing, collections. Before, there was always a department for that. Now it’s all me. I remember one day my website went down and I had no idea what to do. I looked up the error code, and ChatGPT walked me through fixing it. I was so relieved. 

Now I’m thinking about the next chapter: building a team, figuring out benefits and HR. It’s a whole new set of challenges I never had to think about before. 

Jennifer: That’s the part nobody fully prepares you for. Let’s switch gears and talk about the industry more broadly. The articles lately range from alarming to doomsday. Average age of CPAs creeping up, 70% expected to retire in the next eight to ten years, regulatory pathways that are outdated and expensive. Almost every CPA I know well has been absorbed by a merger or private equity at this point. How do you see it shaking out? 

Francheska: Technology is a big part of the answer. You have to embrace it, or you’ll fall behind. Used the right way, with strong safeguards around security and client data, it’s really like having an extra person on your team. 

On the talent side, I sit on the URI accounting board, so I hear about this firsthand. The next generation doesn’t want to just crunch numbers. They want to analyze, think critically, and do more meaningful work. The challenge is giving them a strong foundation while also showing them the bigger picture. If a client asks them to walk through a tax return, they need to be able to do that with confidence. 

As for consolidation and private equity, colleagues who’ve been through it tell me the same thing: it becomes very numbers-driven, and you have to hit your targets. I understand the business reasons behind that, but I believe in serving the client whether it takes five hours or twenty. If a client keeps coming back because they didn’t understand my explanation the first time, I can’t charge them for that. That’s on me. 

Jennifer: That resonates with me. When we take over from other bookkeeping firms, sometimes the bar has been so low that simply responding to someone’s calls or emails is seen as a differentiator. And it shouldn’t be. That’s just basic service. 

Francheska: Exactly. I’ve had prospective clients tell me they were just relieved I called them back, and I hear that far more often than I should. Even when I don’t have the capacity to take someone on, I still respond and point them in the right direction. That’s part of being in a service business. 

Jennifer: Let’s talk about AI since you touched on it. We hear constantly that bookkeeping is going to be replaced in the next eighteen months. I don’t agree. When AI can sit across from a client for thirty minutes and walk them through their financial statements in a way that speaks specifically to how that person thinks and communicates, then we can have a real conversation. How do you see it in your world? 

Francheska: I don’t see it as a threat either. It’s about knowing how and when to use it. For research, there are some incredible tools out there, and I set mine up to rely only on primary sources, not secondhand information. But I also have clients bringing me AI-generated research and asking me to fact-check it. One client puts his entire tax return into an AI tool and comes back with a list of questions based on what it told him, and I have to go through every single point. Another used AI to pull together all of his international disclosure documents and asked me to confirm it was right. So clients are using it whether we like it or not. 

Our role is to evaluate what they bring in, confirm what’s right, and correct what’s wrong, and that takes real expertise. AI can’t represent a client before the IRS or a state tax agency, and it can’t take responsibility for the advice. It also doesn’t know a client’s full history the way their advisor does. It’s a tool, and a useful one, but it’s still just a tool. 

Jennifer: Completely agree. We treat it like a new employee. Trust but verify. Walk me through your work, how did you get to this answer. It’s a good thought partner but it still needs oversight. 

Is there anything we didn’t cover that you want people to know about your new firm or about international tax more broadly? 

Francheska: Yes. I want people to know that international tax goes well beyond the obvious situations. If you’re marrying someone who isn’t a U.S. citizen, receiving a gift or inheritance from someone overseas, or have any assets or income outside the U.S., your ears should perk up. These situations can carry significant penalties if they aren’t reported, and often there’s no tax owed at all. It’s purely a reporting requirement. 

On top of that, if certain international forms aren’t filed, the IRS can keep your entire tax return open for review indefinitely. So whenever something in your life isn’t purely domestic, even if you’re not sure it matters, it’s worth a quick conversation with someone who can tell you whether you have an obligation. A short consultation is always going to be less painful than discovering a problem years later. 

Jennifer: That is such an important point. We see it with sales and use tax all the time. There are situations where you have to disclose even when you owe nothing, and the penalty for not disclosing can be significant. When in doubt, be proactive. Thank you so much for doing this. You are my go-to for all things international and I’m so excited for this new chapter for you. 

Francheska: Thank you so much, Jennifer. That means a lot coming from you. I’m excited for what’s ahead, and I appreciate you having me on. 

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