Notes from the practice.
Long-form pieces on the questions clients actually wrestle with. Written in the same voice we use across the table, by the practitioners who do the work. No content marketing.
What the new 2026 US tax rule (NCTI) means if you own a company abroad.
Net CFC tested income (NCTI) replaced GILTI for tax years beginning after December 31, 2025. It taxes US shareholders of controlled foreign corporations on the company’s earnings each year, and it is not just a rate change: the base is broader, the deduction smaller, and the foreign tax credit more generous.
June 2026
7 min read
ReadForm 5472 for foreign-owned US LLCs: when it applies, and whether the $25k penalty is real.
Form 5472 reaches two kinds of US LLCs: a single-member LLC wholly owned by a foreign person (a foreign-owned disregarded entity, filing with a pro forma Form 1120), and an LLC taxed as a corporation that is 25% or more foreign-owned (filing with its actual 1120). Even funding your own LLC counts as a reportable transaction, and the $25,000 penalty per missed filing is real.
June 2026
6 min read
ReadQualifying for Panama's Pensionado visa without a traditional pension.
You can qualify for Panama’s Pensionado visa without a traditional pension, but only with income that is guaranteed for life, typically at least $1,000 per month. Ordinary 401(k) withdrawals, rental income and portfolio yields do not qualify. A properly structured lifetime annuity can, and for some applicants, the Friendly Nations employment route, real work in a real Panamanian operating business, is the better path entirely.
June 2026
7 min read
ReadDoes Panama tax foreign income? The territorial system, explained honestly.
Panama taxes only income produced within Panamanian territory; foreign-source income is generally exempt. Sourcing turns on where activity happens and where it takes effect, not where clients sit. Two caveats: new economic-substance rules tax certain multinational-group passive income at 15% from 2027, and your home country's rules still apply.
June 2026
7 min read
ReadThe Section 128.1 trap most departing Canadians don't see.
Canada has an exit tax. It is not optional, and it is far broader than most relocation guides admit. Here is what we model before we move a single client.
April 2026
8 min read
ReadUS LLC vs Panama Corporation: which structure is right for your business?
Two flagship structures, two very different jobs. The US LLC buys market access; the Panama S.A. buys territorial-tax efficiency and flexibility. In practice the strongest answer is usually a hybrid, and it depends on how, and where, you actually do business.
April 2026
6 min read
ReadPanama vs Dubai: where should you incorporate in 2026?
Dubai won the branding war on tax-free living. But in 2026 the UAE runs a 9% corporate tax with activity lists and substance rules, while Panama's territorial system taxes only Panama-source income with no thresholds. Past the hype, the mechanics favour Panama for most Western-oriented founders.
April 2026
7 min read
ReadPanama Residency vs Panama Tax Residency: The Difference That Costs People Money
Panama residency and Panama tax residency are two different legal statuses granted by two different authorities. A residency permit comes from immigration. Tax residency generally requires 183 or more days of physical presence in Panama, or a demonstrated center of vital interests there [Código Fiscal, Art. 762-N]. Holding a PR card alone gives you neither, and assuming otherwise is expensive.
June 2026
6 min read
ReadI Live Abroad With a US LLC, Do I Owe US Tax? (The ECI Question)
If you are a non-resident alien who owns a US LLC, single-member or multi-member, you owe US income tax only on income that is effectively connected with a US trade or business (ECI) [IRC §§864(c), 871(b)]. Selling to US customers from abroad is not, by itself, ECI. This article gives you the test and the three rules that decide it.
June 2026
7 min read
ReadIs 25% the Final Canadian Tax on Your RRSP After You Leave? (Section 217)
Often, but not always. Canada withholds a flat 25% on RRSP withdrawals by non-residents, and if you do nothing, that is the final tax [ITA s. 212(1)(l)]. But the Section 217 election lets low-income non-residents file a Canadian return and recover part of it. Whether it pays depends entirely on your numbers.
June 2026
7 min read
ReadAm I a Covered Expatriate? How the US Exit Tax and the Covered-Expatriate Tests Actually Work
You are a covered expatriate if you renounce US citizenship, or give up a long-held green card, and meet any one of three tests: net worth of $2 million or more, average annual US income tax above an inflation-adjusted threshold ($211,000 for 2026), or failure to certify five years of tax compliance. Covered expatriates face the section 877A exit tax.
June 2026
9 min read
ReadWhat Is the Streamlined Filing Compliance Procedure for Unfiled FBARs (and Back Tax Returns)?
The Streamlined Filing Compliance Procedures let US taxpayers whose past failure to report foreign accounts and income was non-willful catch up by filing 3 years of returns and 6 years of FBARs with a non-willful certification [IRS Streamlined Filing Compliance Procedures]. Taxpayers abroad meeting the non-residency test pay no penalty; those at home pay a 5% penalty [IRS Streamlined Foreign and Domestic Offshore Procedures].
June 2026
9 min read
ReadCan I Provide Services to a US Company Tax-Free?
If you are not a US person and you do the work outside the United States, your fee is foreign-source income, so the US does not tax it and there is no US withholding. It is not automatically tax-free everywhere, because your own country may tax it, though a territorial country like Panama generally does not tax foreign-source income.
June 2026
6 min read
ReadHow to Buy Property in Panama as a Foreigner (2026 Guide)
Foreigners can fully own titled property in Panama with the same rights as citizens, no residency required. Here is the process, the real costs, the taxes you owe afterward, and the mistakes that catch foreign buyers.
June 2026
8 min read
ReadTitled Property vs Rights of Possession in Panama: What Buyers Must Know
Titled property is real, registered ownership. Rights of possession is only a right to occupy state land, with no title, no mortgage, and far weaker protection. Here is how to tell which one you are being offered.
June 2026
5 min read
ReadHow to Avoid Real-Estate Scams When Buying Property in Panama
Most Panama property scams are ordinary due-diligence failures dressed up as bad luck. Here are the traps that catch foreign buyers and the checklist that stops them.
June 2026
5 min read
ReadPanama Property Taxes Explained: What Foreign Owners Actually Pay (2026)
Panama's annual property tax is low, and on a primary home it can be close to zero. Here are the two rate schedules, how to claim the primary-residence rate, and the quirks that keep your bill down.
June 2026
5 min read
ReadMoving to Panama: The Complete Relocation Guide (2026)
A clear, ordered relocation plan: choose your residency route, apostille your documents, line up healthcare and banking, then decide what to ship and where to live. Most moves take months, not weeks.
June 2026
7 min read
ReadHow Much Does It Cost to Buy an Apartment in Panama City? (All-In)
The all-in cost to buy an apartment in Panama City is the sticker price plus roughly 3 to 5 percent for closing costs if you pay cash, and closer to 5 to 7 percent if you finance. Here is every line, and who actually pays it.
June 2026
7 min read
ReadIs Panama Real Estate a Good Investment in 2026? (An Honest Take)
Panama real estate can be a good investment in 2026, but only if you buy for cash flow and currency safety rather than fast appreciation, and only if you buy titled stock in the right location. A measured yes, with real conditions attached.
June 2026
7 min read
ReadCosta del Este vs Punta Pacifica: Which Is Better to Buy In?
Costa del Este vs Punta Pacifica usually comes down to one question: are you buying for a family, or for healthcare and ocean views? Here is the price, lifestyle and resale head-to-head, with a clear verdict framework.
June 2026
7 min read
ReadBest Areas to Buy Property in Panama City (An Expat Buyer's Guide)
There is no single best area to buy in Panama City, only the best one for your priorities. This guide profiles each neighborhood, who it suits, and a rough price band so you can match the area to what matters to you.
June 2026
8 min read
ReadHow Much Money Do You Need to Retire in Panama?
Most couples retire comfortably in Panama on $2,000 to $3,500 a month, and a single person on $1,500 to $2,500, with housing the line item that moves the number most. Here is the real monthly math, broken out by category.
June 2026
9 min read
ReadHealthcare in Panama for Expats and Retirees: Hospitals, Insurance and Real Costs
Private care in Panama City is genuinely good, often US-affiliated, and a fraction of US prices, while the public system is cheap but basic. The catch: the best care concentrates in the capital, so where you live matters as much as what you pay.
June 2026
9 min read
ReadMoving to Panama from the US: A Step-by-Step Guide
Moving to Panama from the US works best as a sequence, not a scramble: pick a residency route, time a scouting trip, sort shipping, pets, banking, healthcare and housing, then handle the practical first 90 days.
June 2026
8 min read
ReadHow Do You Open a Panama Bank Account as a Foreigner?
Opening a Panama bank account as a foreigner is doable, but approval is discretionary and the compliance bar is high. Get your documents right, choose the right bank, and use a local attorney to introduce you.
June 2026
8 min read
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In closing
Let’s talk.
A single conversation usually clarifies more than a month of research. We engage on a value basis, and every introduction begins with a direct, confidential exchange.
We advise on
- 01Cross-Border Tax
- 02International Corporate Advisory
- 03Multi-jurisdictional Asset Structuring
- 04Panama Relocation
Rothbard Group S.A.
A boutique cross-border tax and corporate advisory firm. Licensed U.S. Enrolled Agent authorized to practice before the Internal Revenue Service.