#multi-currency
Multi-currency accounting, foreign exchange gains and losses, period-end revaluation, and functional currency considerations
US freelancers billing foreign clients must convert income to USD at the exchange rate on the day of receipt, pay self-employment tax regardless of the client's location, and may owe an FBAR filing if combined foreign-held balances (e.g. in Wise or Payoneer) exceed $10,000 at any point in the year.
Dynamic currency conversion (DCC) marks up foreign-card payments 3-7% above the interbank rate — sometimes 12-18% — and splits the revenue among DCC providers, acquirers, and merchants. Here is who profits, the Visa/Mastercard disclosure rules merchants must follow, and how to book DCC rebates and settlement variances separately from sales revenue.
A letter of credit is a bank's guarantee to pay an exporter once shipping documents match its terms exactly — issuance typically costs 0.75%-2% of the transaction, and the ICC estimates 60-70% of first-time document presentations get rejected for discrepancies.
A 2026 walkthrough of Form 5471 after the One Big Beautiful Bill Act — QBAI is repealed, GILTI becomes NCTI, the Section 250 deduction drops to 40%, the FTC haircut tightens to 10%, and the pro rata share rule moves to daily ownership.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.
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.
How wine and spirits importers and beverage distributors build defensible books—segregating bonded vs. tax-paid inventory, accruing CBMA excise tax refunds under ASC 450, remeasuring foreign-currency payables under ASC 830, reconciling TTB Form 5000.24 to the general ledger, and tracking the cases-per-rep, depletion rate, and gross-profit-per-case KPIs the industry actually lives by.
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 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 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.
ASC 815 requires derivatives to be marked to market through earnings unless you elect hedge accounting at inception. A guide to the three hedge models, the simplified approach for private companies, and the documentation mistakes that turn a clean economic hedge into quarterly earnings volatility.
Form 6166 is the IRS-issued certificate of U.S. tax residency that unlocks reduced foreign withholding under bilateral tax treaties. Apply with Form 8802 — $85 for individuals, $185 for entities — and one filing covers unlimited countries and certificates, often saving five or six figures per cross-border contract.
Form 6166 is the IRS letter that lets U.S. taxpayers claim treaty rates on foreign royalties, dividends, and services. This guide walks through the Form 8802 application, eligibility rules, common rejection traps, and the timing required to get withholding right at the source.
