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International Tax

Everything About International Tax

11 articles
Cross-border tax compliance, foreign income reporting, and US international tax obligations for individuals and corporations

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.

Form W-8BEN and W-8BEN-E: How US Businesses Pay Foreign Vendors Without Triggering 30% Withholding

US payers must collect a valid W-8BEN or W-8BEN-E from a foreign vendor before paying, or the IRS treats the payment as subject to 30% withholding plus Form 1042-S penalties. This guide walks through which form to use, how to claim treaty benefits, the three-year refresh cycle, FATCA classification, and the five documentation mistakes that turn routine vendor onboarding into an audit problem.

HTS Codes and Tariff Classification for Small Importers in 2026: Why Importer of Record Liability Persists Even When You Use a Customs Broker

How the 10-digit Harmonized Tariff Schedule, Chapter 99 add-ons, and Section 301 layers assign legal duty liability to the importer of record—not the broker—and how a prior disclosure under 19 U.S.C. § 1592(c)(4) can cap penalties at interest if you find errors before CBP audits.

Form 5472 for Foreign-Owned US LLCs: The $25,000 Penalty Trap That Catches Single-Member Disregarded Entities Off Guard

Foreign owners of US single-member LLCs must file Form 5472 by April 15, 2026, even with zero revenue. A capital contribution as small as $1 triggers the requirement, and a missed filing carries a $25,000 minimum penalty plus uncapped $25,000 continuation fees every 30 days after IRS notice.

Form 1042-S Withholding on Payments to Foreign Persons: A Compliance Guide for US Businesses

Form 1042-S reports US-source FDAP income paid to foreign persons. US businesses act as withholding agents with personal liability — default 30% withholding, W-8 documentation rules, March 15 deadlines, and stiff per-form penalties. This guide covers W-8BEN versus W-8BEN-E, treaty rate reductions, the source-of-income rules, and common mistakes like sending Form 1099 to a foreign contractor.

GILTI and the Section 962 Election: How US Shareholders of Foreign Corporations Can Slash Their Tax Bill

A Section 962 election lets US individual owners of a controlled foreign corporation be taxed on GILTI/NCTI at corporate rates, cutting the effective US rate from up to 37% to roughly 12.6% in 2026. The OBBBA reduced the Section 250 deduction to 40%, eliminated the QBAI carve-out, and raised the indirect foreign tax credit cap from 80% to 90% — but PTEP rules can still trigger a second layer of US tax when earnings are eventually distributed.

The PFIC Form 8621 Tax Trap: Why US Investors Get Punished for Owning Foreign Mutual Funds and ETFs

PFICs (foreign mutual funds, UCITS ETFs) trigger Section 1291 tax for US investors — gains allocated across the holding period, taxed at top ordinary rates, plus compounded interest charges. This guide covers Form 8621, the QEF and mark-to-market elections, the $25k/$50k de minimis filing exception, and how to escape the trap.