International Tax Services

Foreign Nationals in the U.S.

F-1, H-1B, L-1, O-1, or green-card holders trying to figure out whether you're a resident or non-resident for tax purposes — and what that means for your foreign income, accounts, and home-country assets.

U.S. Citizens with Foreign Assets

Offshore bank accounts, brokerage, retirement plans, foreign real estate, or entity interests that may trigger FBAR (>$10K), Form 8938, Form 5471, Form 3520, or PFIC reporting on top of your U.S. return.

Dual Citizens and Green Card Holders

Two passports or a green card plus foreign ties — balancing U.S. worldwide taxation with home-country obligations, treaty tiebreakers, and the risk of being taxed on the same income twice.

Immigrants and New Residents

First-year U.S. filers navigating the residency-start-date rules, pre-arrival income, foreign retirement accounts, and the dual-status return. Mistakes here compound for years.

Cross-Border Business Owners

Foreign-owned U.S. LLCs or C-Corps, U.S. owners of foreign entities, or dispatch/e-commerce/service operations that cross borders. Forms 5471, 5472, and GILTI are usually in play — and the penalties start at $25,000.

Expats and Relocation Clients

Moving in, out, or back — the transition year is where costly mistakes happen. FEIE vs. FTC, state-residency exit, totalization agreements, and clean first- or last-year filings handled end-to-end.

FBAR Filing (FinCEN 114)

Required when the aggregate value of your foreign accounts crossed $10,000 at any point during the year — even for a single day. Includes checking, savings, brokerage, some retirement accounts, and signature-authority accounts you don't own.

Penalty awareness: Non-willful penalties start at $12,906+ per account, per year; willful exposure reaches 50% of the account balance.

FATCA (Form 8938)

Specified foreign financial assets reporting attached to your Form 1040. Thresholds range from $50,000 (single, U.S.-resident) to $600,000 (married filing jointly, living abroad) in aggregate account value at year-end or peak.

Penalty awareness: Failure-to-file starts at $10,000 and escalates to $50,000 for continued non-compliance.

Form 5471 — Foreign Corporations

U.S. informational reporting for officers, directors, and 10%+ shareholders of foreign corporations across five filer categories. Schedule complexity depends on your category and whether the entity is a CFC.

Penalty awareness: $10,000 per form, per year, with $10,000 stacking every 30 days after IRS notice (capped at $50,000 per form) and a 10% foreign tax credit reduction.

Form 5472 — Foreign-Owned U.S. Entities

Reportable-transaction disclosures for U.S. entities with 25%+ foreign ownership, including foreign-owned single-member LLCs filing pro forma Form 1120. Capital contributions, loans, and distributions all count as reportable transactions.

Penalty awareness: $25,000 per form, per year — automatically assessed by the IRS and stacking every 30 days of continued non-compliance.

Foreign LLC and Corporation Review

Entity classification (per se vs. elective), check-the-box analysis, and filing-posture review for owners running operations outside the U.S. Includes pre-formation structure guidance and reconciling mismatches between U.S. and home-country treatment.

Penalty awareness: Incorrect entity treatment can cascade into missed Forms 5471/5472/8865 and create multi-year exposure.

CFC / GILTI Exposure Review

Controlled Foreign Corporation analysis plus current-year income inclusion for Subpart F and GILTI (Global Intangible Low-Taxed Income). Includes evaluating the Section 962 election, High-Tax Exception, and the reshaping of GILTI under OBBB.

Penalty awareness: Missing this analysis can add six-figure phantom income to your return — or leave real tax liabilities unplanned and unfunded.

Treaty-Based Positions

Claiming benefits under a U.S. tax treaty — residency tiebreakers, reduced withholding rates, pension-article coverage, and permanent-establishment analysis — with proper Form 8833 disclosure where required.

Penalty awareness: Undisclosed treaty positions carry a $1,000+ penalty per position for individuals ($10,000 for C-Corps) and increased audit risk.

Foreign Tax Credits (Form 1116)

Foreign Tax Credit strategy to eliminate double taxation when foreign taxes were already paid on the same income. Includes basket-sorting (passive, general, GILTI, treaty-resourced), sourcing analysis, and FEIE-vs.-FTC modeling.

Penalty awareness: Poor sourcing and documentation can forfeit otherwise valid credits and convert a zero-tax return into a five-figure liability.

Foreign Pension Analysis

U.S. treatment of foreign retirement structures — Canadian RRSPs, UK SIPPs, Australian Super, EU personal pensions, and foreign employer plans. Includes determining whether the plan is a grantor trust, a qualified employer arrangement, or a PFIC wrapper.

Penalty awareness: Pension misclassification is one of the most common high-cost errors — Form 3520/3520-A penalties alone start at $10,000.