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Multi-Currency

Multi-currency accounting, foreign exchange gains and losses, period-end revaluation, and functional currency considerations

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Form 8858 for Foreign Disregarded Entities and Foreign Branches: A Practical Filing Guide for Expat Founders, Multinationals, and U.S. LLC Owners Abroad

Form 8858 reports foreign disregarded entities and foreign branches on a U.S. return, and missing one carries a $10,000 penalty per entity per year that can snowball to $50,000 after IRS notice. This guide covers who must file, Schedules C through M, Section 987 currency calculations, the Schedule K-2/K-3 box 11 connection for Category 6 filers, and the four paths back into compliance.

mike

tax-complianceinternational-taxexpatriate

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

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

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.

mike

tax-complianceinternational-taxexpatriate

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.

mike

international-taxforeign-corporationstax-planning
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