Our Entire Focus

International Tax Specialist

International tax is what we do. It's not a sideline, it's our entire focus. Qorri Tax Service is built around one thing: cross-border tax compliance. I started as the first international tax hire at Plante Moran, then scaled through multinational engagements at Grant Thornton and Dean Dorton.

Whether you’re a U.S. expat, a foreign national with U.S. filing obligations, or a business with cross-border operations, I handle FBAR, FATCA, treaty elections, foreign tax credits, and the full range of international reporting. Every engagement is handled personally, with the precision these filings demand.

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Tajma Qorri
FORTUNE 100 FEATURE
10+ YEARS AT PLANTE MORAN · GRANT THORNTON · DEAN DORTON
FILED IN ALL 50 STATES
Important clarification: International tax here means U.S. tax returns with international complexity, including foreign income, foreign accounts, treaty positions, and cross-border compliance. For Canadian, UK, EU, or other foreign country returns, I coordinate with local advisors in the client's jurisdiction. Alongside your international work, I prepare your full U.S. return, including federal, state, and estimated taxes, so you're not juggling multiple preparers.

How Tajma Helps by Situation

Foreign Nationals in the U.S.

Tajma helps determine residency posture, filing obligations, and cross-border reporting for first-year and continuing filings. You get a clear plan for what applies and what does not.

U.S. Citizens with Foreign Assets

Foreign accounts, pensions, and entity interests are reviewed under FBAR, FATCA, and return-level reporting rules. The process is structured to reduce penalty exposure and filing confusion.

Dual Citizens and Green Card Holders

Tajma coordinates filing strategy across potentially overlapping tax systems and documentation rules. The goal is defensible compliance with practical execution.

Immigrants and New Residents

New U.S. residents are guided through first-year filing choices, timing, and required reporting forms. You get a roadmap, not a guess.

Cross-Border Business Owners

If you own or control a foreign corporation or foreign LLC, Tajma helps evaluate U.S. reporting requirements including Forms 5471 and 5472 and related corporate disclosures.

Expats and Relocation Clients

Relocation often triggers filing complexity that generic preparers miss. Tajma helps manage the transition with practical deadlines and clean reporting.

International Services Breakdown

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.

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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.

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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.

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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.

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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.

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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.

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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.

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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.

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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.

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Frequently Asked Questions

What is FBAR, and do I need to file one?
FBAR (FinCEN Form 114) is required if the combined value of your foreign financial accounts exceeded $10,000 at any point during the year, even for a single day. This includes checking, savings, brokerage, and certain retirement accounts, as well as accounts where you have signature authority but are not the owner. If you have any foreign accounts, it is worth confirming whether this applies to you.
What is FATCA, and how is it different from FBAR?
FATCA requires reporting specified foreign financial assets on Form 8938, which is filed with your tax return. The thresholds are higher than FBAR: $50,000 for single U.S. residents, up to $600,000 for married couples filing jointly and living abroad. FBAR goes to FinCEN (Treasury), while Form 8938 goes to the IRS with your return. Many taxpayers need to file both.
What happens if I have not been reporting my foreign accounts or income?
The IRS offers several paths to come into compliance, including the Streamlined Filing Compliance Procedures, which cap penalties at 5% of account value, or zero if you qualify as a foreign filer. The key is to come forward voluntarily before the IRS contacts you. Waiting increases both penalties and risk.
How do foreign tax credits work to prevent double taxation?
If you have already paid taxes to a foreign country on the same income, the Foreign Tax Credit (Form 1116) lets you offset your U.S. tax liability dollar for dollar, up to certain limits. Proper sourcing and basket classification (passive, general, GILTI) determine how much credit you can use. Done correctly, most clients avoid paying tax twice on the same income.
Can tax treaties reduce what I owe in the U.S.?
Yes. The U.S. has income tax treaties with dozens of countries that can reduce withholding rates, resolve residency conflicts, and protect certain types of income like pensions or scholarships. Claiming treaty benefits requires proper disclosure on Form 8833. An undisclosed treaty position carries its own penalty, so documentation matters.
Do I need to report foreign rental income or real estate on my U.S. return?
Yes. As a U.S. taxpayer, you must report worldwide income, including foreign rental income. Foreign real estate itself is not reported on FBAR or Form 8938, but the income it generates is taxable. If the property is held through a foreign entity, additional reporting (Forms 5471, 8865, or 3520) may apply.
Why should I use an international tax specialist instead of my regular tax preparer?
International tax forms carry penalties starting at $10,000 per form, per year, and the rules are complex enough that general preparers frequently miss required filings or misapply treaty provisions. A specialist who works with these forms daily catches issues that surface only under examination. The cost of specialist preparation is typically a fraction of the penalty exposure from a missed form.

International tax is too important to leave to non-specialists.

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