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International Tax Technical Update- September 2018


On December 22, 2017, the enactment of tax reform (also known as the Tax Cuts and Jobs Act) brought about widespread changes to includable and excludable items, with moving expenses being one of the most notable. Read more

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Foreign Entity Filings- Forms 8865 and 8858

8865 and 8858

U.S. taxpayers who do business globally are well aware of the tax implications involved. Forms 8865 and 8858 are lesser known, but important for foreign corporations to understand.

By Bethany Bouw, CPA

Taxpayers who have foreign businesses are often surprised to hear there are filing requirements to disclose their business. If you are familiar with the basics of international business, you may know this is true of foreign corporations. The same is true of partnerships, sole proprietors, other foreign disregarded entities and more. In many cases, taxpayers assume that if they keep most aspects of their business abroad, that the IRS will have no interest in them. Unfortunately, they are incorrect.

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The GILTI Effect: Tax Reform And Global Intangible Low-Taxed Income

What is GILTI?
The Global Intangible Low-taxed Income (GILTI) is a new provision, enacted as a part of tax reform legislation. Mechanically, it functions as a global minimum tax and introduces a lot of issues for all U.S. shareholders of controlled foreign corporations (CFCs) – especially individuals and partnerships. Read more

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Reporting US Single Member LLCs with Foreign Ownership

Single Member LLC

Reporting your foreign owned single member LLC will be different going forward.

By Bethany Bouw, CPA

If you are a foreign person who has a US single member LLC, there are some new developments that you should be aware of for tax year 2017. Reporting policies regarding foreign ownership of single-member LLCs have recently changed. First and foremost, it is important to know your status – US or foreign. To determine this, you should check the IRS rules and contact a lawyer. Read more

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10 Tips for Reporting Certain Foreign Corporations

Form 5471

Reporting Form 5471 may be confusing, though it is necessary for many who own foreign corporations.

By Bethany Bouw, CPA

Foreign corporations sound innocuous enough but when you delve into the reporting requirements it opens up a Pandora’s box of complex tax issues. There are so many aspects to consider in preparing to report foreign corporations and there has been a lot in the news lately regarding foreign corporations due to the new tax reform. Read more

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International Tax Technical Update- June 2018

IRS Offers Limited Relief to Certain Taxpayers Subject to the Section 965 Transition Tax

June 2018


On June 4, 2018, the Internal Revenue Service (IRS) announced that it will provide penalty relief to certain taxpayers subject to the Section 965 transition tax, and provided additional information for individuals subject to the Section 965 transition tax regarding the due date for relevant elections. Read more

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The Basics of Form 3520

Form 3520

Form 3520 is required for many U.S. taxpayers with international activity. However, there is still a lot of confusion regarding the basics of the form.

By Bethany Bouw, CPA

Many taxpayers with international activity are becoming more familiar with informational reporting on foreign bank accounts, foreign corporations, and foreign financial assets. However, many still struggle with certainty when it comes to reporting transactions with foreign trusts or receipt of foreign gifts/bequests on Form 3520. As with most foreign informational reporting, this is not a form to be ignored or taken lightly as it carries significant penalties. Read more

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Foreign Reporting: Changing Landscape for Forgetful Filers

Foreign Reporting

Changes are on the way for anyone who misses a foreign tax filing deadline.

By Bethany Bouw, CPA

Big changes are coming for those who have missed a foreign filing requirement. As we have previously noted, there are a variety of procedures for becoming compliant. One of those methods will soon be closing, and this may signal additional changes on the horizon. Read more

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Royal Wedding Excitement for the IRS

Royal Wedding

International marriages may be full of romance, but they also lead to complex tax situations that not even royals are immune to.

By Bethany Bouw

Many young, American women perhaps used to imagine what it might be like to marry a prince and live in a faraway kingdom. As the news has been widely covering, one American is about to have that dream come true.  While Meghan Markle prepares for her new fairytale life, she will also be facing the many tax pitfalls of an international marriage. Even those who marry their foreign “prince” and move abroad will have to consider some of the same situations Ms. Markle must now deal with. Here are ten tips for those who, like Ms. Markle, will marry a non-resident and non-citizen, and move abroad. Read more