43 tagged with "International Tax"
Cross-border tax compliance, foreign income reporting, and US international tax obligations for individuals and corporations
FDII to FDDEI: How C Corporations Cut Federal Tax to 14% on Form 8993 in 2026
Under OBBBA, Section 250 renames FDII to FDDEI, sets the deduction at 33.34%, eliminates the QBAI offset, and removes interest and R&E allocation — producing an effective 14% federal rate on qualifying foreign-derived income for U.S. C corporations filing Form 8993 in 2026.
FDII and Form 8993: How U.S. C Corporations Hit a 13.125% Effective Tax Rate on Foreign Sales
A working guide to the FDII (now FDDEI) deduction on Form 8993 — which U.S. C corporations qualify, how the Section 250 math drops the effective federal rate to 13.125% on foreign-derived income, the taxable income limitation, documentation the IRS expects, and how OBBBA simplifies the calculation starting in 2026 by removing the QBAI step and expense allocations.
The IC-DISC: How Closely Held Exporters Cut Federal Tax on Export Profits to 23.8%
The IC-DISC is the only permanent federal tax incentive dedicated to U.S. exporters that is available to pass-through entities. It routes export commissions through a tax-exempt paper corporation and back out as qualified dividends, cutting the effective federal rate on export profits from roughly 40% to 23.8% for closely held manufacturers, distributors, software vendors, and engineering firms.
The IC-DISC Export Tax Strategy: How Closely-Held U.S. Exporters Cut Their Tax Rate on Foreign Sales to 20 Percent
An IC-DISC is a paper-only U.S. C corporation authorized by IRC Sections 991–997 that lets closely-held manufacturers, distributors, and growers convert qualifying export profit from ordinary income rates (up to 37%) into qualified dividend rates (20–23.8%), with typical setups producing $50,000+ in annual federal tax savings on $5M of qualifying export sales after Section 199A's 2026 sunset widened the rate spread.
Schedules K-2 and K-3: The Domestic Filing Exception, the 1-Month Rule, and the $250,000 Small-Entity Carve-Out for 2026
How U.S. partnerships and S corporations qualify for the Schedule K-2/K-3 domestic filing exception, manage the 1-month-date partner request rule, and use the new small-entity exception for entities with under $250,000 in total receipts.
Subpart F Income and Controlled Foreign Corporations: Why U.S. Owners Get Taxed on Foreign Profits Before the Cash Comes Home
Subpart F forces U.S. shareholders of a controlled foreign corporation to recognize foreign profits as current-year income, even when no cash is distributed. This guide covers the 10 percent threshold, the four triggering income categories, Section 958 constructive ownership traps, Form 5471 penalties, and how the 2026 OBBBA rewrite (NCTI, restored 958(b)(4), 40 percent Section 250 deduction) reshapes the rules.
Subpart F Income and CFC Rules: U.S. Tax on Foreign Corporation Profits Under NCTI in 2026
How U.S. shareholders of foreign corporations are taxed on undistributed profits in 2026: the 10 percent threshold, Section 958 constructive ownership, Form 5471 filing duties, and the OBBBA rewrite that replaced GILTI with Net CFC Tested Income (NCTI).
FIRPTA Withholding: The Buyer's 2026 Guide to Section 1445 and Form 8288
FIRPTA requires US real estate buyers to withhold 15 percent of the gross sale price from foreign sellers and remit it on Form 8288 within 20 days of closing. This guide explains Section 1445, the $300,000 personal residence exemption, the 10 percent reduced rate, withholding certificates on Form 8288-B, and how buyers avoid personal liability with an Affidavit of Non-Foreign Status.
Foreign Tax Credit vs. Foreign Earned Income Exclusion: Which Should Expats Pick in 2026?
A side-by-side guide to Form 1116 (Foreign Tax Credit) and Form 2555 (Foreign Earned Income Exclusion) for expats and cross-border workers in 2026 — the $132,900 FEIE cap, the five-year revocation lock-in, the FTC stacking rule, and a worked example showing when each one actually saves money.
Form 8832 Entity Classification Election: How LLCs and Foreign Entities Use the Check-the-Box Rules
Form 8832 lets eligible entities — domestic LLCs and most foreign companies — elect to be taxed as a disregarded entity, partnership, or C corporation. This guide covers default classifications, the 60-month lockout, late-election relief under Rev. Proc. 2009-41, and how Form 8832 differs from Form 2553.
Streamlined Filing Compliance Procedures: How Non-Willful US Taxpayers Catch Up on FBAR, Form 8938, and Three Years of Late Returns Without Crushing Penalties
How non-willful US taxpayers use the IRS Streamlined Filing Compliance Procedures to catch up on FBAR, Form 8938, and three years of late returns—zero penalty under SFOP for taxpayers abroad, a one-time 5% miscellaneous offshore penalty under SDOP for domestic filers, plus what the non-willfulness certification must demonstrate.
Transfer Pricing for Small Multinationals: Section 482, OECD Pillar Two, and Defensible Documentation
Section 482 reaches any small multinational with intercompany transactions, and missing Forms 5472 carry $25,000 penalties each. A working guide to the arm's-length standard, the five transfer pricing methods, contemporaneous documentation, and how OECD Pillar Two affects US-headquartered groups in 2026.