#multi-currency
Multi-Currency
Multi-currency accounting, foreign exchange gains and losses, period-end revaluation, and functional currency considerations
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.
ASC 815 Hedge Accounting for Private Companies: Document Swaps and Forwards Without Wrecking Earnings
ASC 815 requires derivatives to be marked to market through earnings unless you elect hedge accounting at inception. A guide to the three hedge models, the simplified approach for private companies, and the documentation mistakes that turn a clean economic hedge into quarterly earnings volatility.
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.
Foreign Tax Credit vs. Foreign Earned Income Exclusion: Which Should Expats Pick in 2026?
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.
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.
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.
Foreign Exchange Gains and Losses: A Practical Multi-Currency Accounting Guide for Small Businesses
How small businesses record foreign exchange gains and losses under US GAAP (ASC 830) and IRC Section 988, with sample journal entries, realized vs. unrealized treatment, period-end revaluation, and a practical monthly close workflow.