U.S. Taxes for Americans Living in Brazil: The 2026 Guide

Key takeaways

• US citizens and green card holders living in Brazil generally still file a US return every year, because the US taxes on citizenship and status, not on where you live.
• Brazil generally taxes its tax residents on worldwide income, and residency can begin on arrival or after 183 days, depending on your visa and employment.
• With no income tax treaty, double-tax relief rests on unilateral rules: the US foreign tax credit or exclusion on one side, and Brazil's recognition of US "reciprocity" on the other.
• Since 2024, Brazil taxes residents' foreign financial investments, including US brokerage accounts, at a flat 15% each year, which changes the math for many Americans.
• The totalization agreement, not the (nonexistent) tax treaty, decides whether you pay US Social Security tax, Brazilian INSS, or both.

Do Americans living in Brazil still file US taxes?

Generally, yes. The US taxes citizens and green card holders on worldwide income wherever they live. Only formally giving up that status ends the obligation (see "Leaving Brazil").

Filing thresholds. The filing threshold is tied to your filing status and the standard deduction, which is indexed annually. For tax year 2026, Rev. Proc. 2025-32 sets the standard deduction for married couples filing jointly at $32,200. Self-employed people generally must file if net self-employment earnings are $400 or more, regardless of the income threshold.

Deadlines for tax year 2026:

• Regular due date: April 15, 2027.
• Automatic two-month extension to June 15, 2027, if on April 15 you live outside the US and your main place of business or post of duty is outside the US. You attach a statement explaining that you qualify. Interest still runs from April 15 on any tax not paid by then.
• Further extension to October 15, 2027, by filing Form 4868 (an extension to file, not to pay). Taxpayers abroad can also ask for two more months, to December 15, by letter to the IRS.
• FBAR (FinCEN Form 114): due April 15, with an automatic extension to October 15.

Indexed amounts. The Foreign Earned Income Exclusion is $132,900 for 2026 ($130,000 for 2025) and changes yearly.

When does Brazil treat you as a tax resident, and what does it tax?

Residency is a tax test, not an immigration status. Brazil's rule is in Instrução Normativa SRF nº 208/2002, articles 2 and 3. In summary:

• With a permanent visa (now generally "residence authorization" under current immigration law), you are generally a tax resident from the date of arrival.
• With a temporary visa, you generally become a tax resident when you complete 184 days in Brazil, consecutive or not, within any 12-month period. You become resident earlier if, before day 184, you obtain a permanent visa or an employment relationship ("vínculo empregatício").
• Until then, a temporary-visa holder who stays up to 183 days in a 12-month period is a nonresident.

A binding Receita ruling (Solução de Consulta Cosit nº 180/2021) confirms that an immigration rule granting a visa does not override IN 208/2002. It concerned a real estate investor visa. No Receita guidance specific to the digital nomad visa (Resolução CNIg nº 45/2021) addresses the point, so the general temporary-visa rule applies: residency starts on day 184. Whether a contract with a foreign employer counts as the "vínculo empregatício" that triggers earlier residency is not addressed by any ruling. The wording of IN 208/2002, which refers to a temporary visa issued to work with an employment link, suggests it means Brazilian work-visa employment, but that is a reading of the text rather than a settled interpretation.

What Brazil taxes: worldwide income. The charging provision is article 43 of the Código Tributário Nacional (CTN). Its §1 provides that the tax applies regardless of, among other things, "a localização ... da fonte" (the location of the source). Receita rulings apply this, together with Lei nº 7.713/1988, to income a resident receives from abroad (for example, Solução de Consulta Cosit nº 61/2018). Brazil is therefore a worldwide system for residents, not a territorial or remittance system.

How foreign income is taxed in Brazil.

• Foreign salary, pensions and rent are generally taxed monthly through the carnê-leão at progressive rates, due by the last business day of the following month, then reconciled on the annual return.
• Foreign financial investments and controlled foreign entities, since January 1, 2024, fall under Lei nº 14.754/2023: income is taxed annually at a flat 15%, separately from other income, on the annual return, with foreign exchange variation included in the gain. Losses within this category can offset gains.

Rates (calendar year 2026). The monthly progressive table runs from 0% up to 27.5% above R$4,664.68 of monthly taxable income, unchanged from 2025 per Receita's published tables. Lei nº 15.270/2025, signed November 26, 2025 and effective January 1, 2026, adds a reduction that effectively exempts monthly income up to R$5,000 and phases out at R$7,350. The same law introduced, from 2026, a 10% withholding on dividends above R$50,000 per month from a single company and a minimum tax on annual income above R$600,000. Details remain contested among practitioners.

Local filing. The annual return (Declaração de Ajuste Anual) for calendar 2025 was due May 29, 2026. The 2027 deadline for calendar 2026 had not been announced when this guide was last verified. You need a CPF (Brazilian taxpayer number) for almost everything.

Is there a US–Brazil tax treaty?

No. As of October 2026, no comprehensive income tax treaty between the US and Brazil is in force; Brazil is absent from the IRS treaty list. A Tax Information Exchange Agreement (in force since 2013) and the FATCA agreement exchange information but do not reduce tax; the totalization agreement covers social security only. In practice:

• No tie-breaker and no saving clause. For a US citizen dual residency rarely matters, because the US taxes you anyway. There are no reduced treaty withholding rates either.
• Pensions and dividends. There is no treaty article exempting a Brazilian pension, INSS benefit, or local retirement plan from US tax. Without a treaty, dividends from a Brazilian company are "qualified dividends" only if its stock is readily tradable on an established US securities market, for example as NYSE-listed ADRs, and the company is not a PFIC in that year or the prior year (IRC §1(h)(11)(C)).

Unilateral relief that applies instead.

• US side: the foreign tax credit (IRC §§901–909) and the Foreign Earned Income Exclusion (IRC §911).
• Brazil side: Brazil credits foreign income tax paid in a country that grants reciprocity (IN SRF 208/2002, art. 1). Ato Declaratório SRF nº 28/2000 recognizes reciprocity with the United States, so US federal income tax can be credited against Brazilian tax, within limits. That recognition does not extend to US state or local taxes. Lei nº 14.754/2023 also provides for a credit of foreign tax against the 15% tax on investment income.

Some Brazilian commentators argue that the 2022 US foreign tax credit regulations undermine the reciprocity on which the 2000 declaration rests, and that Brazil could in theory revoke it. As of this writing it has not been revoked, and the IRS has indefinitely extended temporary relief from those regulations (Notice 2023-80, extending Notice 2023-55).

How do you avoid paying tax twice?

For the general mechanics of the FEIE, the Foreign Tax Credit and the stacking rule outside Brazil-specific figures, see our guide on FEIE vs. Foreign Tax Credit.

Foreign tax credit versus exclusion. You can exclude up to $132,900 of foreign earned income in 2026 on Form 2555 if you meet the bona fide residence or physical presence test, or credit foreign income taxes on Form 1116. Income you exclude cannot also be used to claim a credit for the tax on it.

Which tends to fit in Brazil.

• With a 27.5% top rate, wage earners taxed in Brazil on their full salary often find the foreign tax credit eliminates US tax and builds excess credits.
• The exclusion can suit people with low Brazilian tax, such as before Brazilian residency starts or when income falls in the bands exempted by Lei 15.270.
• The exclusion does not reduce US self-employment tax; for that, see the totalization agreement below.
• Revoking the exclusion after electing it generally bars re-electing it for five years without IRS approval.

Baskets and carryovers. Credits are computed separately by category under IRC §904(d); for most individuals the relevant ones are passive income (interest, dividends, most gains) and general income (wages, business income). Unused credits carry back one year, then forward ten.

The US-source problem. Dividends from US companies in a US brokerage account are US-source, so the US gives no foreign tax credit on them. Brazil taxes the same income at 15% and relieves the double tax by crediting the US tax under reciprocity. With no treaty there is no resourcing rule, so run the numbers on both returns.

Timing. The tax years match. Brazil's return is due in late May, before the June 15 extended US deadline, so Brazilian figures can usually be finalized first. Cash-basis US taxpayers can elect to claim credits on an accrual basis. The election is made by checking the "Accrued" box on a timely filed original return and binds all later years.

Brazilian taxes that are not creditable. INSS contributions are social security contributions, not income tax. No US credit or deduction is allowed for social security taxes paid to a country, like Brazil, that has a social security agreement with the US.

Social security: will you pay both?

The totalization agreement decides this. It is a separate instrument from any income tax treaty. It entered into force on October 1, 2018. It does not cover Brazil's FGTS severance fund.

Employees. The general rule assigns coverage to the country where you work. The main exception is the "detached worker": an employee sent by an employer from one country to work temporarily in the other for five years or less generally stays covered only by the home country. An employee of a US company's foreign affiliate may also stay in US coverage if the US company agrees to treat the worker as its employee for this purpose.

Self-employed people: the sources disagree.

• The SSA's public agreement page says self-employed workers who reside in Brazil are assigned Brazilian coverage, and those who reside in the US are assigned US coverage.
• SSA's internal manual (POMS RS 02002.435, 2019) says a self-employed worker is generally covered by the country where the work is performed, with a five-year exception for a temporary transfer of self-employment activity.

The agreement as published in Brazil (Decreto nº 9.422/2018, art. 5) assigns self-employed people to their country of residence, which matches the SSA public page. Both readings point to Brazil for someone who lives and works there.

Claiming the exemption.

• From US tax, if Brazil covers you: request a Brazilian certificate of coverage from the Brazilian authority. A self-employed US citizen generally still files a US return, indicates on Schedule SE that the earnings are exempt under the agreement, and attaches a copy of the Brazilian certificate.
• From Brazilian INSS, if the US covers you: your employer, or you if self-employed, requests a US certificate of coverage from SSA, including online at opts.ssa.gov.

Effect on benefits. Either country can count credits from the other to qualify you for a partial benefit; US claims use Form SSA-2490-BK.

Remote workers for US employers. Under the agreement, an employee working in Brazil is generally covered by Brazil, unless posted for five years or less with a US certificate of coverage. Brazilian law has no category written for a resident employed by a foreign company with no Brazilian establishment. The common reading is that the worker contributes as a contribuinte individual, paying 20% of earnings up to the INSS ceiling, though no Receita or INSS ruling confirms this category, so it remains unsettled. If Brazil covers you under the agreement, ask your US employer whether to stop FICA withholding.

Which US forms apply to accounts and assets in Brazil?

• FBAR (FinCEN Form 114): required if the combined maximum value of your foreign financial accounts exceeds $10,000 at any time in the calendar year. Brazilian checking, savings, CDB, brokerage and investment fund accounts generally count.
• Form 8938: for taxpayers living abroad, the threshold is more than $200,000 on the last day of the year or $300,000 at any time (single or married filing separately), and $400,000/$600,000 for married filing jointly. These thresholds are not indexed and have been unchanged for years.
• Local banks and US persons. Under the Model 1 FATCA agreement (in force June 26, 2015), Brazilian banks report US account holders to the Receita Federal, which passes the data to the IRS.
• CRS. Brazil exchanges information with other CRS jurisdictions; the US is not a CRS participant.

Brazilian reporting you may also owe. Your Brazilian annual return lists assets and rights worldwide, including US accounts and property. Separately, the Banco Central do Brasil requires residents holding US$1 million or more abroad on December 31 to file the Declaração de Capitais Brasileiros no Exterior (CBE); for the 2025 base date, the window ran from February 15 to early April 2026. It is a statistical filing, not a tax return, but missing it carries fines.

Local pensions, retirement accounts and investment funds

INSS benefits. A Brazilian social security pension is generally taxable in the US, with no treaty exemption. Absent a treaty, foreign social security benefits are taxable as annuities, not under the US Social Security rules of IRC §86.

PGBL and VGBL plans. Under Brazilian law, both are contracts with an insurer or an open pension company (a sociedade anônima), whose reserves are invested in dedicated funds (FIEs) owned by the insurer. A PGBL is a pension plan; a VGBL is legally a life insurance product with survival coverage. Their US treatment is unsettled:

• No IRS ruling, private letter ruling, chief counsel advice or court case specific to PGBL or VGBL addresses them.
• Practitioners variously treat them as foreign trusts (Forms 3520 and 3520-A), as foreign annuity or insurance contracts whose yearly growth may be taxable if they fail US insurance definitions, or as direct holdings of underlying funds that are PFICs (Form 8621). None of these views has IRS backing.
• Favorable Brazilian treatment does not by itself defer US tax, and there is no treaty provision to do so.
• Rev. Proc. 2020-17 probably does not help: it exempts certain tax-favored foreign retirement trusts from Forms 3520/3520-A, but only for arrangements that are trusts, with contributions limited to earned income and capped, and withdrawals restricted to retirement, disability or death or penalized. Neither plan has a statutory contribution cap or an early-withdrawal penalty, so both likely fail, VGBL most clearly — a reading of the revenue procedure's text, not a conclusion any IRS guidance has reached.
• Reporting applies either way. The Form 8938 instructions treat an interest in a foreign pension plan as reportable, and cash-value insurance and annuity contracts as financial accounts; the FBAR instructions likewise include insurance and annuity policies with a cash value. So both plans are generally reportable on Form 8938 (above the thresholds) and FBAR, whatever their income tax treatment.

US retirement accounts (401(k), IRA, Roth IRA). Lei 14.754/2023 and IN RFB nº 2.180/2024 expressly list foreign "fundos de aposentadoria ou pensão" as financial investments. Income from them is counted in the year it is actually received. The better reading is therefore that Brazil taxes a resident at 15% on distributions, not each year on growth inside the account. Three points are unsettled: whether a self-directed account could fall under the rule that taxes yearly any account in which the investor steers the investments; how Roth contributions and amounts already taxed in the US are treated; and which rate applies, since an older Receita Q&A answer points distributions of foreign pensions to monthly carnê-leão at progressive rates rather than the 15% flat rate. No Receita ruling on 401(k)s or IRAs resolves these.

Brazilian investment funds are generally PFICs. A Brazilian mutual fund or ETF is usually a foreign corporation for US purposes earning passive income, which makes it a PFIC. That brings Form 8621 and, absent an election, punitive tax and interest on distributions and gains. For the full mechanics of the default regime and the available elections, see our guide on PFICs. Direct Tesouro Direto bonds or bank CDBs are not PFICs.

Running a business or company in Brazil

Check classification first. The Brazilian Sociedade Anônima (S.A.) is on the US "per se" corporation list (Treas. Reg. §301.7701-2(b)(8)). It is always a corporation for US purposes and cannot elect otherwise. Other forms, such as the Sociedade Limitada (Ltda.), are eligible entities: under the default rules a foreign eligible entity whose owners all have limited liability is generally treated as a corporation, but it can elect partnership or disregarded status on Form 8832. Limited liability is judged under Brazilian law. Do not assume a CFC until you have done this step.

If it is a corporation you control (more than 50% owned by US shareholders, each owning at least 10%), it is a controlled foreign corporation. You may then have Form 5471 reporting, Subpart F inclusions, and the regime formerly called GILTI, renamed net CFC tested income (NCTI) for tax years beginning after December 31, 2025, with the old 10% tangible-asset carve-out removed. Individuals pay NCTI at ordinary rates with no indirect credit for Brazilian corporate tax unless they make a Section 962 election. The high-tax exclusion may also be relevant.

Brazilian side. A Brazilian resident who controls a company outside Brazil can be taxed annually at 15% on its profits under Lei 14.754/2023.

Self-employment tax. Sole proprietors and disregarded entities owe US self-employment tax unless a Brazilian certificate of coverage exempts them.

Buying, renting and selling property

Selling your home: US side. The Section 121 exclusion ($250,000; $500,000 joint) requires a principal residence owned and used for two of the last five years; the statute does not limit where the home is. IRS Publication 523 does not address foreign homes expressly. Gain is computed in dollars, so a weaker real can shrink a gain that looks large in reais.

Selling your home: Brazilian side. Capital gains on real estate are taxed at progressive rates from 15% to 22.5%. Two main exemptions apply to residents: sale of your only property for R$440,000 or less, if you made no other property sale in the previous five years; and reinvestment of the proceeds in residential property in Brazil within 180 days of the sale contract, with partial reinvestment giving a proportional exemption. A Brazilian exemption leaves no Brazilian tax to credit against any US gain beyond Section 121.

Currency gain on a reais mortgage. IRC §988 itself excludes an individual's personal transactions, and its legislative history says pre-1986 principles govern a foreign-currency mortgage on a principal residence. Under those principles, if the real weakens before you repay, the dollars saved are generally treated as taxable gain. That position is widely followed but rests on old case law rather than a statute or regulation. A currency loss on such a mortgage is not deductible: Quijano v. United States, 93 F.3d 26 (1st Cir. 1996), denied it as a personal loss under IRC §165(c) and treated the loan as separate from the home sale.

Rental income. In Brazil, rent from individuals is generally paid through carnê-leão at progressive rates. In the US, report it on Schedule E; foreign residential rental property is generally depreciated over 30 years under the alternative depreciation system, which is mandatory for property used predominantly outside the US. Brazilian tax on the rent is generally creditable in the passive or general basket, depending on your activity.

Employment, equity compensation and remote work for a US employer

Source rule. Pay for work physically performed in Brazil is generally foreign-source for US purposes, wherever the employer is, so it qualifies for the exclusion or credit.

Remote work for a US employer. Once resident, salary from abroad is generally subject to carnê-leão in Brazil. A US employer may keep withholding US income tax, reconciled on your US return.

RSUs and stock options. In the US, RSUs are generally taxed at vesting as wages, sourced by where you worked during vesting. In Brazil, the Superior Tribunal de Justiça held in 2024 (Tema 1226, REsp 2.069.644/SP) that stock option plans are commercial, not pay: no income tax is due when the shares are acquired, only on a gain when they are sold. The Supreme Court declined to review that decision in 2025. The decision concerns options for which the employee pays an exercise price. RSUs, delivered free, remain contested: the Receita and the administrative tax tribunal (CARF) have treated them as pay at vesting, taxable through carnê-leão at progressive rates, while taxpayers argue Tema 1226 applies to them by analogy. When you later sell shares of a foreign company you do not control, the gain is taxed at 15% as a financial investment, and the R$35,000 monthly exemption for small sales does not apply. Take advice before your first vest.

State tax. Moving abroad does not automatically end US state tax residency — see our guide on state taxes after moving abroad.

Leaving Brazil

Brazilian side. Leaving permanently requires two separate filings with the Receita Federal: the Comunicação de Saída Definitiva do País, due by the last day of February of the year after you leave; and the Declaração de Saída Definitiva do País, covering the months you were resident. The instruction sets the last business day of April, but the Receita aligns it each year with the annual return deadline (May 29 in 2026). Any tax due is payable by that date. Secondary sources that give February for both filings confuse the two.

If you leave temporarily, nonresidency generally starts after 12 months of absence. If you do not file, Receita may keep treating you as resident. Brazil has no exit tax on individuals: neither IN 208/2002 nor Lei 14.754/2023 taxes unrealized gains on departure.

US side. Leaving Brazil changes nothing for US filing. Renouncing citizenship or abandoning long-term green card status can trigger the expatriation regime of IRC §877A. For 2026, the exclusion amount for covered expatriates is $910,000, and the average-annual-tax test is $211,000. Both are indexed annually. See our guide on the US exit tax.

Mistakes Americans commonly make in Brazil

1. Assuming a treaty exists. Relief depends on unilateral credits and reciprocity.
2. Missing the start of residency after 183 days or on signing a Brazilian employment contract.
3. Ignoring the 15% annual tax on US brokerage accounts under Lei 14.754.
4. Skipping the monthly carnê-leão on foreign salary or rent.
5. Buying Brazilian funds or a VGBL without checking PFIC and trust rules.
6. Using the exclusion to cut self-employment tax. It does not; use a certificate of coverage instead.
7. Forgetting the CBE filing once foreign assets reach US$1 million.
8. Leaving without the saída definitiva filings.

Checklist

Before moving: map when Brazilian residency starts; get a CPF; request a US certificate of coverage if transferred; gather cost basis for US investments; list all accounts and entities.

First 90 days: track days in Brazil; set up carnê-leão once resident; request a Brazilian certificate of coverage if self-employed.

Every year: CBE (February to early April, if applicable); US return April 15 or June 15 and FBAR; Brazilian return in late May; keep proof of tax paid in each country.

Before leaving: file the Comunicação and Declaração de Saída Definitiva; settle carnê-leão and the 15% tax to the departure date; review how pensions and funds will be taxed after departure.

Frequently asked questions

Do I have to file taxes in both the US and Brazil?

Generally yes, once you are a Brazilian tax resident.

Is there a tax treaty between the US and Brazil?

No, only a totalization agreement and information-exchange agreements.

Can I use the Foreign Earned Income Exclusion in Brazil?

Yes, if you meet the residence or presence test, though the foreign tax credit often works better.

Does Brazil tax my US brokerage account?

Generally yes: 15% a year under Lei 14.754/2023, with a credit for US tax.

Will I pay Social Security in both countries?

Usually not, but you generally need a certificate of coverage.

Is my PGBL or VGBL tax-deferred in the US?

Not automatically; its treatment is unsettled.

When to hire a professional

• Cross-border tax adviser (US CPA or enrolled agent plus a Brazilian contador): your first Brazilian year, or US investments plus Brazilian residency.
• US international tax attorney: a controlled Brazilian company, NCTI, Section 962, foreign trusts, late filings — see our guide on the Streamlined Filing Compliance Procedures if several years were missed.
• Brazilian tax lawyer: Lei 14.754 entities, equity compensation, residency disputes, saída definitiva.
• Payroll or social security specialist: remote work for a US employer.

Sources

Source	URL	Used for	Page date
IRS — Tax Treaty Table 3	https://www.irs.gov/pub/irs-lbi/table-3-list-of-tax-treaties.pdf	No Brazil treaty	Updated through 26-Sep-2025
IRS — United States income tax treaties A to Z	https://www.irs.gov/businesses/international-businesses/united-states-income-tax-treaties-a-to-z	No Brazil treaty	Accessed 17-Oct-2026
SSA — Totalization Agreement with Brazil (Pub. EN-05-10167)	https://www.ssa.gov/international/documents/EN-05-10167.pdf	Totalization agreement text	Accessed 17-Oct-2026
US Treasury — FATCA agreements table	https://home.treasury.gov/about/offices/tax-policy/foreign-account-tax-compliance-act	Model 1 IGA, in force 26-Jun-2015	Accessed 17-Oct-2026
26 CFR §301.7701-2 (via Cornell LII)	https://www.law.cornell.edu/cfr/text/26/301.7701-2	S.A. per se corporation	Accessed 17-Oct-2026
GTN — US-Brazil totalization alert	https://www.gtn.com/brazil-us-social-security-totalization-agreement	Entry into force date, FGTS exclusion	Accessed 17-Oct-2026
Instrução Normativa SRF nº 208/2002 (texte officiel, miroir)	https://www.normasbrasil.com.br/norma/?id=74786	Residency rules, reciprocity, departure	2002
Ato Declaratório SRF nº 28/2000 (texte officiel, miroir)	https://www.contabeis.com.br/legislacao/5990/ato-declaratorio-srf-28-2000/	Reciprocity recognition with the US	2000
Lei nº 14.754/2023 (Planalto)	https://www.planalto.gov.br/ccivil_03/_ato2023-2026/2023/lei/l14754.htm	15% annual tax on foreign investments/CFEs	2023
IN RFB nº 2.180/2024 (texte consolidé)	https://www.normaslegais.com.br/legislacao/instrucao-normativa-rfb-2180-2024.htm	Mechanics of Lei 14.754, foreign retirement accounts	2024
Ministério da Fazenda — Q&A on Lei nº 14.754/2023	https://www.gov.br/fazenda/pt-br/assuntos/noticias/2023/dezembro/qa-lei-14754-offshores2.pdf	Official explanation of the 15% regime	2023
Solução de Consulta Cosit nº 61/2018; nº 7/2019; nº 180/2021; nº 130/2026 (reproduites)	https://www.ibet.com.br/?p=82946	Worldwide taxation, carnê-leão, residency, equity sales	2018–2026
Lei nº 9.250/1995 art. 23; Lei nº 11.196/2005 art. 39; Solução de Consulta Disit/SRRF02 nº 2.001/2025	https://www.ibet.com.br/sc-disit-srrf-02-no-2001-2025-irpf-ganho-de-capital-isencao-direito-hipotese-alienacao-de-unico-imovel-do-titular-valor-da-alienacao-ate-r-440-mil-inexistencia-de-alienacao-anterio/	Real estate sale exemptions	1995–2025
IRS — Rev. Proc. 2025-32; Rev. Proc. 2020-17; Notice 2023-80	https://www.irs.gov/pub/irs-drop/rp-25-32.pdf	2026 figures, foreign retirement trust exemption, FTC regs relief	2020–2025
IRS — Publications 54, 514, 515, 523, 527	https://www.irs.gov/publications/p54	Filing rules, FTC, home sale, rental depreciation	12/2025
Quijano v. United States, 93 F.3d 26 (1st Cir. 1996)	https://law.resource.org/pub/us/case/reporter/F3/093/93.F3d.26.96-1053.html	Currency loss on foreign mortgage	1996
STJ — Tema 1226 (REsp 2.069.644/SP)	https://processo.stj.jus.br/repetitivos/temas_repetitivos/pesquisa.jsp?novaConsulta=true&tipo_pesquisa=T&cod_tema_inicial=1226&cod_tema_final=1226	Stock option plans not taxed as pay at grant/exercise	2024
Decreto nº 9.422/2018; Lei nº 8.212/1991; Lei Complementar nº 109/2001 (Planalto/Câmara)	https://www.planalto.gov.br/ccivil_03/leis/l8212cons.htm	Totalization text, INSS contributions, private pension law	1991–2018
Mattos Filho; Contábeis; Fenacon; Migalhas; Forvis Mazars; Schlam Stone (secondary)	—	Issue-spotting only: Lei 15.270 dividend/minimum tax, filing deadlines, CBE window, NCTI/Section 962, Form 8938 thresholds	2024–2026

A note on scope: this guide is general information, not tax or legal advice. Whether a given fact pattern — a VGBL policy, a controlled Brazilian company, a Receita residency determination — triggers the rules described here depends on your own situation. Get advice from a US preparer experienced with Forms 1116, 5471, 8621 and 8938 and a Brazilian contador before you rely on anything in this guide.