Dividend Withholding: 30% to 5%
Serbian DOO ownership through a U.S. S-Corp created unnecessary withholding drag in a no-treaty context. We redesigned the structure with a Dutch blocker and aligned U.S. C-Corp ownership for foreign assets.
Every client situation is unique, but patterns emerge. These case studies illustrate how Qorri Tax has helped clients resolve complex tax issues—from penalty abatement and late FBAR filings to multi-year catch-up programs and cross-border restructuring.
Names and details have been changed to protect client privacy, but the outcomes are real.
Serbian DOO ownership through a U.S. S-Corp created unnecessary withholding drag in a no-treaty context. We redesigned the structure with a Dutch blocker and aligned U.S. C-Corp ownership for foreign assets.
An e-commerce owner was absorbing avoidable self-employment tax as an LLC. We moved to an S-Corp model and implemented a compliant reasonable-compensation payroll workflow.
A client received a foreign inheritance and did not file Form 3520 on time. We rebuilt the documentary record, corrected reporting posture, and executed a defensible remediation sequence.
Three years of missed Form 5472 filings required rapid correction and clean coordination with return-level reporting. We prepared and submitted the backlog with a complete technical file.
A UK startup entered the U.S. without a reliable tax structure and with nexus uncertainty. We defined filing posture, implemented proper entity and reporting setup, and stabilized compliance from day one.
A dual citizen had ten years of unfiled FBAR obligations. We assembled account history, structured streamlined disclosure, and coordinated final reporting submission.
I will map scope, forms, and timeline before filing deadlines create avoidable exposure.
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