Guides, tools, and tips to help you navigate tax season, manage your books, and grow your business with confidence.
Practical explanations for businesses and families, with primary sources and related reading.
If a foreign-owned U.S. corporation or single-member LLC missed Form 5472, the penalty is generally $25,000 per form for each year, with more after an IRS notice goes unanswered. Routine first-time abatement is not automatic; limited related-return relief may apply. The usual route is to file every missing year with a reasonable-cause statement, ideally before the IRS makes contact.
Read guide →Cross-Border BusinessA U.S. corporation with at least 25% foreign ownership, or a foreign-owned U.S. disregarded entity, may need Form 5472 for reportable related-party transactions. A disregarded entity files it with a pro forma Form 1120. Failure to file correctly can trigger a $25,000 penalty, even without income tax due.
Read guide →Cross-Border BusinessU.S. transfer-pricing rules generally require controlled transactions to reflect an arm’s-length result. There is no universal small-business revenue exemption or safe markup. Identify the services, goods, financing and risks involved, then support the pricing method. Adjustments may create tax, interest and penalties; documentation is important but does not guarantee protection.
Read guide →Cross-Border BusinessU.S. persons with interests in foreign corporations should test the Form 5471 filing categories, including certain 10% ownership events and control. A CFC generally involves more than 50% U.S.-shareholder ownership by vote or value, subject to attribution rules. Some failures carry an initial $10,000 penalty; the required schedules depend on the category.
Read guide →Explore our existing cross-border audit services.
You may need both. FBAR generally applies when a U.S. person’s aggregate foreign financial accounts exceed $10,000 at any time during the year. Form 8938 has separate asset thresholds and accompanies an income tax return. Filing one does not replace the other; penalties and filing channels also differ.
Read guide →Individuals & FamiliesBefore year-end, review projected income, withholding, estimated payments, investment gains, gifts and foreign reporting together. There is no single high-net-worth filing threshold. Each form has its own test, and late payments or missing international information can create separate penalties. Prioritize decisions that must occur before December 31, then document the follow-through.
Read guide →Individuals & FamiliesA U.S. person generally reports gifts or bequests exceeding $100,000 from a nonresident alien individual or foreign estate during the year on Form 3520. Related donors may need aggregation. A genuine gift is generally not income, but late reporting can trigger 5% per month, up to 25%, absent reasonable cause.
Read guide →Individuals & FamiliesA foreign corporation can be a PFIC if at least 75% of its income is passive or at least 50% of its assets produce, or are held to produce, passive income. U.S. holders may need Form 8621. Foreign funds and insurance require product-specific analysis; tax-and-interest consequences can apply without a simple flat filing penalty.
Read guide →Individuals & FamiliesStreamlined procedures may help eligible individuals whose offshore omissions were non-willful. They generally cover three tax-return years and six FBAR years, with separate domestic and foreign eligibility rules. The domestic route generally includes a 5% miscellaneous offshore penalty; qualifying foreign submissions can receive broader penalty relief. Eligibility is not automatic.
Read guide →Individuals & FamiliesImmigration status and tax residence are related but not identical. Review the green-card and substantial-presence tests before moving, then inventory foreign accounts, companies, funds, gifts and trusts. The substantial-presence test generally uses 31 current-year days and a weighted 183-day calculation. Missing later tax or information filings can create separate penalties.
Read guide →An LLC is a legal structure; S and C corporation treatment are tax classifications. Nonresident alien shareholders cannot own an S corporation. Compare ownership eligibility, payroll, distributions, investment plans and California costs before electing. There is no universal profit threshold or single penalty that makes one structure best for every business.
Read guide →Business AdvisoryA business may need a fractional CFO when reliable bookkeeping no longer answers decisions about cash, hiring, margins or financing. There is no statutory revenue threshold, filing form or penalty for not hiring one. Start with the decisions you cannot make confidently, then define the reporting, forecasting and meeting cadence needed to support them.
Read guide →We track official IRS and California tax developments and refresh this feed from official sources. Our goal is simple: surface the changes that matter without overwhelming you with noise.
IRS updates are general information. Book a consultation to apply the rules to your specific facts.