Qorri Tax Blog
I write every post here myself. No ghostwriters, no syndicated content. Topics come from the work I do every week: penalty exposures, international reporting traps, deadline mistakes, and IRS developments that actually affect real returns.
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Streamlined Disclosure: How to Fix Years of Missed Foreign Reporting
The IRS streamlined procedures let non-willful taxpayers fix years of missed FBARs, Form 8938, 5471, and 3520 filings with reduced or zero penalties. Who qualifies and how it works.
streamlined disclosureFBARinternational taxcompliance
Read PostStreamlined Filing Compliance Procedures: How to Come Into Compliance
Streamlined disclosure help for U.S. taxpayers with unreported foreign accounts. How the Streamlined Filing Compliance Procedures work, who qualifies, and what filing looks like.
streamlined proceduresforeign accountsinternational taxcompliance
Read PostForm 1116 and the Foreign Tax Credit: How to Avoid Double Taxation
Form 1116 lets U.S. taxpayers claim the foreign tax credit and avoid double taxation. The limitation, income baskets, and carryovers explained.
Form 1116foreign tax creditdouble taxationinternational tax
Read PostForm 8938 and FATCA: How to Report Foreign Financial Assets
FATCA requires U.S. taxpayers to report foreign accounts, foreign stock, and foreign pensions on Form 8938. Who must file, the thresholds, and the $10,000 penalty for skipping it.
Form 8938FATCAinternational taxforeign assets
Read PostForm 3520: Foreign Gifts, Inheritances, and Trust Reporting
A foreign inheritance is not taxable income, but failing to report it on Form 3520 can trigger a penalty of up to 25%. Who must file, the dollar thresholds, and how to fix a missed year.
Form 3520international taxforeign giftsforeign trusts
Read PostYour Foreign-Owned LLC Needs Form 5472. Here's What Happens If You Skip It.
Form 5472 is required for every foreign-owned U.S. LLC, even with no income. The penalty for skipping it is $25,000 per year. A Form 5472 specialist explains who files, what triggers it, and how to fix missed filings.
Form 5472international taxpenaltiesforeign-owned LLC
Read PostWho Needs to File Form 5471 — And What Happens If You Don't
Most people who need to file Form 5471 don't find out until a $10,000 penalty notice arrives. Here's how to know if you're required to file — and what to do if you've already missed it.
Form 5471international taxpenaltiesCFC
Read PostThe June 15 Expat Deadline Trap: Why Your “Automatic” Extension Isn’t Saving You What You Think
The June 15 expat filing deadline is real and automatic. But the cost of being late starts running long before June 15. Five traps every U.S. expat should know.
expatdeadlinesFEIEFBARForm 4868
Read PostYou Don’t Have to Intend to Break the Law to Face the Maximum FBAR Penalty
The Second Circuit confirmed that reckless disregard of FBAR requirements triggers the maximum willful penalty. If you have unreported foreign accounts, the “I didn’t know” defense is functionally closed.
Read PostMoved to the U.S. in 2025? Your First Tax Return Checklist Before April 15
If you moved to the U.S. in 2025, your first filing year is not a standard return.
Read PostBefore You File: 10 International Tax Deadline Mistakes to Catch Before April 15
When a return involves foreign income, foreign accounts, foreign entities, or foreign assets, deadline pressure can create very expensive mistakes.
Read PostMissed the March 15 Deadline? Here's What to Do Next
March 15 was the filing deadline for S-Corporations (Form 1120-S) and partnerships (Form 1065). If your entity has foreign ownership or cross-border transactions, the stakes are significantly higher.
Read PostHiring Foreign Contractors? What U.S. Companies Get Wrong About 1042 Withholding
The companies we work with are not careless. They are building products, serving customers, and growing teams across borders.
Read PostForm 5471 and GILTI: What Every Tax Practitioner Needs to Know This Tax Season
Every March, the same thing happens. A tax firm discovers that a client they've been filing for years actually owns shares in a foreign corporation.
Read PostThe IRS Is Sharing Taxpayer Data. Here's What International Tax Clients Need to Know.
The IRS Is Sharing Taxpayer Data. Here's What International Tax Clients Need to Know.
Read PostThe 3 International Tax Penalties That Can Bankrupt a Small Business - And How to Avoid Them
There's a particular kind of phone call I've been getting for over a decade. A business owner - usually sharp, usually successful - calls because they just received a notice from the IRS.
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