#international-tax
International Tax
Cross-border tax compliance, foreign income reporting, and US international tax obligations for individuals and corporations
Form 6166 U.S. Residency Certification: How Businesses and Individuals Use Form 8802 to Slash Foreign Withholding on Royalties, Dividends, and Service Income
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 and Form 8802: How U.S. Residents Cut Foreign Withholding by Certifying Tax Residency
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.
The U.S. Exit Tax in 2026: How Form 8854 and Section 877A Tax You on the Way Out
Section 877A treats covered expatriates as if they sold every asset the day before leaving the United States. For 2026 the net-tax threshold is $211,000, the net-worth test sits at $2 million, and the gain exclusion is $910,000 — here is how Form 8854 decides whether you pay.
Form 8865 Foreign Partnership Reporting: The Four Categories of Filers, the $10,000 Penalty, and How U.S. Persons Stay Off the IRS Radar
Form 8865 is the U.S. information return for foreign partnership interests, with $10,000 per-partnership per-year penalties for non-filing. This guide breaks down the four filer categories under Sections 6038, 6038B, and 6046A, the constructive ownership rules that catch most surprise penalties, and the schedules each category must include.
Form 8865 Foreign Partnership Reporting: The Four Categories of Filers, $10,000 Penalty Trap, and How U.S. Persons Stay Compliant in 2026
Form 8865 makes U.S. persons report controlled foreign partnerships, property contributions, and 10-percentage-point interest changes. Missing it triggers $10,000 per partnership per year, plus a 10% foreign tax credit haircut and stacking 30-day penalties up to $50,000.
Form 8975 and Schedule A: A Practical Guide to U.S. Country-by-Country Reporting for Multinationals in 2026
U.S. multinational groups with $850 million or more in consolidated revenue must file Form 8975 with one Schedule A per tax jurisdiction. This guide walks through the four-part threshold test, the Schedule A line items, the Pillar Two transitional safe harbor that now relies on CbCR data, and the five filing mistakes that most often trigger audits in the 2026 cycle.
Form 8975 Country-by-Country Reporting in 2026: The $850M Threshold, Schedule A Mechanics, and the Pillar Two Safe Harbor
U.S. multinationals with $850M+ in consolidated revenue file Form 8975 with Schedule A per jurisdiction. In 2026 the report also gates the OECD Pillar Two transitional safe harbor at a 17% simplified ETR — making CbC data accuracy a strategic, not clerical, priority.
Schedules K-2 and K-3 in 2026: The Domestic Filing Exception, the 1-Month Deadline, and the Foreign Tax Credit Trap
Schedules K-2 and K-3 pulled even purely domestic partnerships and S-corps into international tax reporting starting in 2021. This guide explains the 2026 filing rules, the four-condition domestic filing exception, the January 15 partner notification and February 15 1-month K-3 request deadlines for calendar-year filers, the $250,000 small entity carve-out added in 2024, and the per-partner, per-month penalty math for non-compliance.
Corporate Alternative Minimum Tax (CAMT): How the 15% Book-Income Levy on $1B+ Companies Actually Works
The Corporate Alternative Minimum Tax imposes a 15% levy on Adjusted Financial Statement Income for corporations averaging over $1 billion in AFSI. A practical guide to who qualifies, how AFSI is computed under section 56A, the FPMG $100M U.S. test, Form 4626 mechanics, and the interim simplified safe harbor.
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.