43 tagged with "International Tax"
Cross-border tax compliance, foreign income reporting, and US international tax obligations for individuals and corporations
W-9 Vendor Onboarding in 2026: TIN Matching, Backup Withholding, and CP2100 Defense
A 2026 walkthrough of W-9 collection, IRS e-Services TIN matching, the 24 percent backup withholding trigger, CP2100 B-Notice timelines, Section 6721 penalty defense, and W-8BEN handling for small businesses paying contractors.
Self-Published Author Bookkeeping: KDP, ACX, Kickstarter, and the Full Indie Publishing Stack
How indie and hybrid authors should track royalties from KDP, ACX, IngramSpark, Patreon, and Kickstarter, classify editors and narrators as 1099-NEC contractors, capture foreign withholding tax under treaty terms, and apply ASC 606 to crowdfunded pre-orders.
Form 5471 in 2026: How the OBBBA Rewrites CFC Reporting, NCTI Replaces GILTI, and What Every 10% U.S. Shareholder Needs to File This Year
A 2026 walkthrough of Form 5471 after the One Big Beautiful Bill Act — QBAI is repealed, GILTI becomes NCTI, the Section 250 deduction drops to 40%, the FTC haircut tightens to 10%, and the pro rata share rule moves to daily ownership. Covers all five filer categories, Schedules J/M/P/Q, Form 8992 and 1118 coordination, Section 989 currency translation, and $10,000-per-CFC penalties.
Bookkeeping for Translators and Court Interpreters: CAT Discounts, ASC 830, and the ABC Test Trap
How freelance translators, court interpreters, and small LSPs should structure their books — entity choice, CAT-weighted revenue, ASC 830 FX accounting, ABC-test worker classification, multi-state nexus, and the KPIs that actually drive per-word yield.
Section 988 Foreign Currency Transactions: A Tax Guide for Importers, Exporters, and Remote Workers
Section 988 of the Internal Revenue Code makes foreign-exchange gains and losses ordinary, not capital. Importers, exporters, and remote workers paid in euros or pounds get full ordinary-loss deductions with no $3,000 cap, a same-day election to convert forward-contract gains to capital, and a $200 per-transaction de minimis exception for personal travel currency.
Form 3520-A: The March 15 Deadline, Substitute Filings, and the 5% Section 6677 Penalty
Form 3520-A is the annual information return for a foreign trust with a U.S. owner, due March 15. If the foreign trustee does not file, Section 6677 imposes an initial 5% penalty on trust assets plus $10,000 per 30-day continuation period — payable by the U.S. owner. Covers who files, the substitute filing path, the reasonable-cause defense, and how to clean up multi-year non-compliance.
Section 7874 Anti-Inversion Rules: 60%/80% Ownership Tests and the Substantial Business Activities Safe Harbor
Section 7874 imposes a 10-year inversion-gain floor when former U.S. shareholders own 60-80% of a new foreign parent and reclassifies the parent as a domestic corporation at 80%. The only escape is the substantial business activities safe harbor, which requires clearing a 25% bright-line threshold on employees, tangible assets, and gross income in the foreign country.
Form 14457 and the IRS Voluntary Disclosure Practice: A Survival Guide for Willful Non-Filers, Crypto Whales, and Offshore Account Holders
How willful non-filers, crypto whales, and offshore account holders use IRS Form 14457 to trade criminal exposure for a defined six-year civil resolution under the Voluntary Disclosure Practice — including the December 2025 proposed framework, disqualifying traps, and when to choose Streamlined or DIIRSP instead.
Form 706-NA: The $60,000 Trap That Can Turn a Foreign Investor's U.S. Real Estate Into a 40% Estate Tax Bill
Nonresident aliens who own U.S. real estate, U.S. corporate stock, or other situs property get only a $60,000 estate tax exemption — not the $13.99 million citizens enjoy in 2026 — and pay up to 40% on the excess. A working guide to Form 706-NA, FIRPTA withholding, treaty relief via Form 8833, transfer certificates, and the blocker-corporation structures that actually work.
Form 8858 for Foreign Disregarded Entities and Foreign Branches: A Practical Filing Guide for Expat Founders, Multinationals, and U.S. LLC Owners Abroad
Form 8858 reports foreign disregarded entities and foreign branches on a U.S. return, and missing one carries a $10,000 penalty per entity per year that can snowball to $50,000 after IRS notice. This guide covers who must file, Schedules C through M, Section 987 currency calculations, the Schedule K-2/K-3 box 11 connection for Category 6 filers, and the four paths back into compliance.
Section 1446(f) Withholding: A Buyer's Guide to the 10% Trap on Foreign Partner Sales of Partnership Interests
Section 1446(f) requires buyers of partnership interests to withhold 10% of the amount realized when a foreign partner sells and remit it to the IRS within 20 days on Form 8288. This guide walks through the six exceptions, the certifications that must be in hand before closing, and the bookkeeping records that defend the position under audit.
Section 245A Participation Exemption: How U.S. C Corporations Repatriate Foreign Profits Tax-Free
Section 245A grants a 100% dividends-received deduction on qualifying foreign dividends to U.S. C corporations, but only when the 365-day holding period, hybrid dividend, extraordinary disposition, and PTEP ordering rules all hold. This guide explains how the participation exemption coordinates with GILTI and Subpart F, the traps that disqualify the deduction, and the bookkeeping that keeps it defensible on audit.