Beyond Accounting Bitesize

Foreign trusts are where some of the most expensive surprises in cross-border tax live. A trust quietly settled overseas — sometimes years before anyone in the family imagined moving to the United States — can trigger deemed realization events, punitive throwback taxes, and reporting obligations that catch families completely off guard.

In the final episode of Navigating the Expatriate Tax Maze, Peter Trieu of BDO walks through:

• What actually makes a trust "foreign" in the eyes of the IRS (the control test and the court test)
• The critical difference between foreign grantor trusts and foreign non-grantor trusts
• How distributions to US beneficiaries are taxed — and why the throwback tax regime is so punishing
• The 5-year rule that pulls pre-immigration trusts back into the US net
• The deemed-sale trap when a foreign grantor trust converts to a non-grantor trust
• Form 3520 and 3520-A reporting requirements every US beneficiary and grantor needs to know

A fitting close to the series — and a reminder that with foreign trusts, planning ahead is everything.

If anything in this series raised questions about your own situation or your employees', Dave Zydek and Peter Trieu welcome a direct conversation. Contact details and the full series are available at cawnetworkusa.com.

Brought to you by CAW Network USA in partnership with BDO.

The US gift and estate tax is one of the most misunderstood areas of cross-border planning — partly because "resident" means something completely different here than it does for income tax. You can be a US income tax resident and still not be domiciled in the US for estate tax purposes, and that distinction can be worth millions of dollars.

In part 4 of Navigating the Expatriate Tax Maze, Peter Trieu of BDO lays out:

• The domicile test for estate and gift tax — a facts-and-circumstances analysis very different from the income tax bright-line rules
• The $15 million lifetime exemption available to US-domiciled individuals
• The much smaller $60,000 exemption that applies to non-residents
• The 40% rate that kicks in above the exemption thresholds
• The curious dual treatment of US stocks — tax-free to gift as intangibles, but fully taxable in the estate at death
• Planning moves for non-residents holding US-situs assets

Short, sharp, and essential for anyone with cross-border family wealth.

Brought to you by CAW Network USA in partnership with BDO.

Giving up US citizenship or handing back a long-held green card sounds like a clean break — but the US tax system has other ideas. Since the HEART Act of 2008, expatriating Americans and long-term green card holders can be hit with a mark-to-market exit tax that treats nearly everything they own as if it had been sold the day before departure.

In part 3 of Navigating the Expatriate Tax Maze, Dave Zydek and Peter Trieu of BDO unpack:

• Who counts as a "covered expatriate" — and the three tests that pull you into the regime (tax liability, net worth, and certification)
• Who qualifies as a long-term green card holder (the 7-year rule)
• What the mark-to-market exit tax actually looks like in practice
• The 30% tax on future distributions from non-grantor trusts to former covered expatriates
• The 40% inheritance-style tax on US persons receiving gifts or bequests from covered expatriates
• Planning moves to avoid covered expatriate status — including primary residence sales, lifetime gifting, and spousal transfers

Essential listening for anyone considering expatriation or advising clients who are.

Brought to you by CAW Network USA in partnership with BDO.

If you're a foreign national living in the United States and you hold a mutual fund, hedge fund, or private equity interest outside the US, there's a very good chance you own what the IRS calls a Passive Foreign Investment Company — or PFIC. The rules around PFICs are among the harshest in the entire US tax code, and getting them wrong can be enormously expensive.

In part 2 of Navigating the Expatriate Tax Maze, Dave Zydek of BDO walks through:

• What actually makes a foreign investment a PFIC (the income test and the asset test)
• The three tax regimes you can fall under: the default method, the QEF election, and the mark-to-market election
• Why the default method can push your effective tax rate above 40% or even 50%
• The Form 8621 disclosure requirements — and why missing one can leave your US tax return open to audit indefinitely
• Common exceptions, including PFICs held inside treaty-recognized retirement plans like UK SIPPs

Practical, plain-English guidance for anyone managing foreign investments while subject to US tax.

Brought to you by CAW Network USA in partnership with BDO.

The US tax system can feel less like a framework and more like a minefield — especially if you're a foreign national living and working in the United States, or an employer responsible for international talent.

In this opening episode of our 5-part series, Navigating the Expatriate Tax Maze, host David Powell introduces your guides: Dave Zydek, Tax Managing Director in BDO's Private Client Services practice, and Peter Trieu, Tax Principal based in San Francisco. Both work daily with high-net-worth individuals and family offices navigating complex cross-border tax issues.

Dave and Peter set the stage, recap the foundational topics covered in part one of this webinar series (available on cawnetworkusa.com), and lay out the four deep-dive topics ahead: passive foreign investment companies (PFICs), the US expatriation tax, gift and estate tax for foreign nationals, and foreign trusts.

Whether you're planning ahead or playing catch-up, this series is packed with practical insights to help you stay compliant and tax-efficient in the US.

Brought to you by CAW Network USA in partnership with BDO.

The U.S. tax system is complex enough for domestic taxpayers — for foreign nationals living and working in America, it can be a whole different challenge. In this episode, BDO's Dave Zydek and Peter Trieu, both specialists in private client tax services, break down the cross-border tax issues that catch expatriates off guard most often.

From understanding your obligations as a U.S. taxpayer to the mechanics of exit tax, passive foreign investment company (PFIC) compliance traps, and the intricacies of foreign trusts, this session covers the issues that matter most — with practical planning strategies you can act on.

Produced in association with BDO as part of a CAW Network USA webinar series. For part one of this series, visit CAWNetworkUSA.com.

What are today’s biggest human skill blind spots?

In the final episode, we explore findings from 2,700+ data points analyzing Gen Z professional development — revealing:

• Decision-making as a strength
• Leadership as a weakness
• Emotional intelligence declining with age
• Feedback avoidance as a critical barrier

Are human skills really measurable — or are they just personality traits?

In this episode, we explore the research behind Livre’s 31-skill human skills framework and how it groups communication, emotional intelligence, leadership, self-management, and more into quantifiable components.

Key insights include:

• Why soft skills feel “fluffy” — and how to demystify them
• The seven core skill categories
• The power of structured experiential learning
• Why AI enables personalized development at scale
• The case for simulation-based learning

If leadership and communication can be broken into repeatable behaviors, they can be trained — and tracked.

This episode moves from problem to practical solution.

Why are technically brilliant professionals struggling in the workplace?

In this episode, Bartek shares the moment that triggered his mission: high-performing audit trainees being removed from client engagements — not for lack of intelligence, but for lack of communication and interpersonal skills.

Drawing on research from Deloitte, Oxford, and global workforce studies, we explore:

• Why “soft skills” should be called human skills
• The generational shift impacting workplace readiness
• The impact of AI and remote work on interpersonal development
• Why 7 of the World Economic Forum’s top 10 skills are human-centered

This episode sets the foundation: technical competence gets you hired — human skills determine your trajectory.

Career Conversations | Chartered Accountants Worldwide Network USA

What happens when a Chartered Accountant decides to swap the audit file for a sales pitch? In the latest episode of our Career Conversations series, Nancy Chakabuda sits down with Breiffni O'Donnell CA — VP of Commercial, Legal & Accounting Solutions at Propylon — for a candid, energising conversation about an unconventional career path, the real value of the CA qualification, and why AI might just be the most exciting thing to happen to the accounting profession in a generation.

A Commerce Graduate Who Didn't Like Accounting (At First)

Breiffni opens the conversation with a refreshingly honest admission: when he was studying at university in Galway, Ireland, he wasn't exactly a fan of his accounting and audit modules. It was a summer placement — implementing a CRM system integrated with an accounting package — that changed everything. Suddenly, he could see what the numbers were actually for: driving real business decisions, building dashboards for leadership, telling the story behind the data. He was hooked.

He went on to qualify with Chartered Accountants Ireland and spent three years in practice at Hogan Associates in Dublin, auditing a diverse portfolio of companies and gaining exposure to business models, revenue structures, and — crucially — how to hold your own in a room with senior executives.

The Phone Call That Changed Everything

Breiffni had made no secret to his partners at Hogan that he wanted to live in New York. They promised to get him there within two years. Thirty minutes later, one of the partners called him back: how would you like to go in six months? The partner had invested in a company — Propylon — that was expanding into the US and needed someone to open their New York office. Breiffni took the leap.

That pivot from audit to sales and business development turned out to be the making of his career. He subsequently worked across several companies in FinTech and LegalTech before returning to Propylon, which was later acquired by global language and content services company RWS. Today, he describes his role not as sales, but as consultative — using his accounting background to speak the language of the firms he works with, build a credible business case, and demonstrate genuine value to finance leaders.

"Accountants Are Some of the Most Exciting People I've Met"

Ask Breiffni about the biggest misconceptions around the profession and he doesn't hold back. Yes, he's heard the "accounting is boring" line — and he firmly disagrees. He points out that a striking proportion of FTSE 500 CEOs have an accounting background, and that the CA qualification does far more than teach you to reconcile a balance sheet. In his view, the strategic thinking and business acumen built into the CA programme is the equivalent of a Master's degree — a foundation that sets you up not just for finance, but for leadership across every sector.

AI, Agentic Tools, and the Need for Guardrails

The conversation takes a fascinating turn when Nancy asks Breiffni about AI. At Propylon, the team builds content management systems specifically for audit, accounting and tax firms — platforms that help organisations keep their policies, methodologies and guidance current across multiple jurisdictions and languages. AI integration is now central to that work.

Breiffni describes two compelling use cases his team has been developing: an AI-powered search tool that references both external standards and internal firm guidance, and agentic AI workflows that can autonomously monitor firm policies, flag outdated content, identify contradictions, and surface potential gaps in regulatory coverage — with a human always in the loop.

But he's also clear-eyed about the risks. He shares a vivid example of an AI agent tasked with maximising profits on a virtual vendi