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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FEIE vs. Foreign Tax Credit: How U.S. Expats Should Choose in 2026
The foreign earned income exclusion and the foreign tax credit both prevent double taxation, but they are not interchangeable. The 2026 exclusion of $132,900, the stacking rule, the refundable child tax credit, and the five year revocation trap that makes this a planning decision.
FEIEforeign tax creditexpat taxinternational tax
Read PostSeptember 15 and October 15: The Deadlines International Filers Still Owe in 2026
An extension moved your filing date, not your obligations. September 15 collects third-quarter estimates and extended entity returns. October 15 collects the extended 1040, Forms 5471, 8938, 3520, 8621 and the FBAR, each with its own penalty for missing it.
deadlinesForm 5471FBARestimated tax
Read PostForeign Real Estate and U.S. Taxes: How to Report Property You Own Abroad
The property abroad usually goes unreported, but the rent, the bank account, the holding entity, the inheritance, and the sale all trigger U.S. filings. Schedule E and ADS depreciation, FBAR and Form 8938, Forms 5471 and 3520, and the Section 988 currency trap at sale.
foreign real estateFBARForm 3520international tax
Read PostForm 8833 and Treaty-Based Return Positions: When a Tax Treaty Claim Must Be Disclosed
Tax treaties can change your residency, exempt your income, or re-source it entirely, but most treaty claims must be disclosed on Form 8833. The residency tie-breaker, the Section 6712 penalty, and the green card trap that can trigger the exit tax.
Form 8833tax treatiesdual residentsinternational tax
Read PostInternational Tax Penalty Abatement: How to Fight Penalties on Forms 5471, 5472, and 3520
IRS penalties for late Forms 5471, 5472, and 3520 are assessed automatically, by computer, but they can be removed. The reasonable cause standard, the four procedural paths, and the mistakes that sink good abatement cases.
penalty abatementForm 5471Form 3520international tax
Read PostForm 8865 Help: What U.S. Partners in Foreign Partnerships Must File
U.S. partners in foreign partnerships must file Form 8865 or face automatic $10,000 penalties. The four filer categories, constructive ownership traps, and how to fix missed years.
Form 8865foreign partnershipsinternational taxpenalties
Read PostPFIC Tax Help: How Passive Foreign Investment Companies Are Taxed and Reported
The U.S. tax rules for passive foreign investment companies are among the harshest in the code. How PFICs are taxed under Section 1291, the QEF and mark-to-market elections, and what Form 8621 requires.
PFICForm 8621international taxforeign funds
Read PostStreamlined 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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