Comment from Your Tax Base

Re: REG IRS-2026-0430-0001, Excise Tax on Remittance Transfers, Proposed Rulemaking Submitter: Justin Malone, Founder, Your Tax Base (https://yourtaxbase.com) On behalf of Your Tax Base, a CPA-backed Florida domicile and virtual mailbox service serving over 500 Americans living abroad, digital nomads, travel nurses, and retirees, we respectfully submit the following comments on the proposed regulations under IRC section that imposes excise tax on certain remittance transfers occurring after December 31, 2025. 1. Definition of remittance transfer in the context of expat banking A large share of our clients maintain US-based checking and savings accounts (Chase, Schwab, Wise) while physically living abroad. Standard expat practice is to receive US-source income (W-2 wages, 1099 contractor payments, Social Security, IRA distributions) into a domestic US account and then transfer funds to a local foreign bank account to pay rent, utilities, and living expenses. Under a plain reading of the proposed rule, every one of these routine wire and ACH transfers may qualify as a remittance transfer and trigger the excise tax. We urge the Service to clarify whether self-transfers between accounts owned by the same US person at different financial institutions are intended to be in scope. Treating self-transfers the same as third-party remittances will impose significant friction on overseas Americans who comply fully with US federal income tax obligations and would create double taxation in substance. For additional context on how this rule interacts with state residency, FEIE, and the day-to-day banking life of overseas Americans, see our published analysis: https://yourtaxbase.com/blog/remittance-tax-2026-guide-expats-nomads 2. Interaction with state residency Many of our clients maintain Florida domicile while physically abroad. State tax authorities in California, New York, New Jersey, Massachusetts, and Illinois actively use remittance and wire records to challenge claims of severed domicile. If the proposed rule produces a new federal reporting layer that state revenue authorities can subpoena, it may inadvertently create new audit exposure for compliant Americans abroad who have legitimately established domicile in zero-income-tax states. We respectfully request the Service consider an exception for documented domicile holders. 3. Compliance burden for small remittance amounts Many of our retired clients transfer modest fixed sums (often less than $2,500 per month) to cover rent and utilities. A flat excise tax without a de minimis threshold disproportionately burdens retirees on fixed incomes living in lower-cost-of-living countries. We suggest adopting a monthly per-person de minimis exemption. 4. Practitioner availability Your Tax Base would be pleased to provide additional client-level data (anonymized) and supporting analysis to Treasury and the Service during the comment process. Respectfully submitted, Justin Malone Founder, Your Tax Base https://yourtaxbase.com justin@yourtaxbase.com St. Petersburg, FL