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#international-tax

International Tax

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

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A 2026 walkthrough of Form 5471 after the One Big Beautiful Bill Act — QBAI is repealed, GILTI becomes NCTI, the Section 250 deduction drops to 40%, the FTC haircut tightens to 10%, and the pro rata share rule moves to daily ownership.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.

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.