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 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.
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.
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.
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.
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.
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 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.
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.
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.