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International Tax

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

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Section 245A Participation Exemption: How U.S. C Corporations Repatriate Foreign Profits Tax-Free

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.

mike

international-taxc-corporationforeign-corporations

Section 367 Outbound Transfer Rules: The Hidden Tax Trap When U.S. Companies Move Stock, IP, or Operations Abroad

Section 367 overrides corporate non-recognition rules the moment U.S. property crosses into a foreign corporation, forcing immediate gain on outbound asset and IP transfers. This guide explains Sections 367(a), (b), (d), and (e), the GRA and Form 8838 deferral path, the 10% Form 926 penalty, the TCJA expansion to goodwill and workforce in place, and the 2024 final regulations on IP repatriation.

mike

taxinternational-taxforeign-corporations

Section 7701(b) Substantial Presence Test for Foreign Entrepreneurs: The 183-Day Formula, Closer Connection, and Treaty Tie-Breakers

A practical walkthrough of IRC Section 7701(b) for globally mobile founders — the 31-day floor, the weighted three-year 183-day formula, exempt-individual rules, the closer connection exception (Form 8840), and treaty tie-breakers (Form 8833) — with a worked example showing how 130 U.S. days in 2026 can trigger worldwide taxation.

mike

international-taxtax-complianceexpatriate

Section 1248 Deemed Dividend on CFC Stock Sales: A U.S. Shareholder's Guide to E&P, GILTI, and PTEP

Section 1248 recharacterizes part of a U.S. shareholder's gain on the sale of CFC stock as a dividend, capped by the corporation's earnings and profits and reduced by PTEP from GILTI and Subpart F inclusions. This guide explains who is affected, how the lookback works, why corporate sellers can prefer the recharacterization for Section 245A, and how to build a defensible work paper.

mike

international-taxforeign-corporationstax-planning

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.

mike

international-taxtax-compliancetax-planning

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.

mike

taxinternational-taxpartnerships

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.

mike

tax-complianceinternational-taxtransfer-pricing

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.

mike

taxtax-compliancepartnerships
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