Category: Articles

Form 5472 is a vital reporting requirement for foreign-owned U.S. entities. While it may seem straightforward at first glance, navigating its complexities is essential to avoid severe penalties and ensure compliance with IRS regulations. Learn about the intricacies of Form 5472, including its requirements, the penalties for noncompliance, the differences in filing for corporations versus…

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The most challenging part of filing a FinCEN BOI form is accurately identifying beneficial owners of reporting companies. This often overlooked step is crucial for complying with the Financial Crimes Enforcement Network’s (FinCEN) Beneficial Ownership Information (BOI) requirements. Who is a Beneficial Owner? A beneficial owner is an individual who directly or indirectly meets one…

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The global economy offers immense opportunities for U.S. business owners to expand their ventures abroad. Whether establishing foreign subsidiaries, opening international bank accounts, or investing in overseas markets, entrepreneurs are increasingly reaching beyond U.S. borders. However, this international reach comes with tax reporting obligations that many business owners inadvertently neglect. This oversight can lead to…

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The Corporate Transparency Act (CTA) has been making waves in the business world, and its impact is about to become even more pronounced. With the Financial Crimes Enforcement Network (FinCEN) requiring businesses to submit their Beneficial Ownership Information (BOI) by January 1, 2025, organizations of all sizes need to be prepared. There have been tons…

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As 2024 winds down, many entrepreneurs and business owners are pondering the best time to incorporate or change their business entity. If you’re gearing up to launch in 2025 or considering changing your existing structure, the timing of your incorporation can significantly impact your taxes and administrative requirements. Should you rush to incorporate before year-end…

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The Foreign Investment in Real Property Tax Act (FIRPTA) has long been a cornerstone of U.S. tax policy on foreign investments in U.S. real property. Under FIRPTA, foreign investors disposing of U.S. real property interests (USRPIs) are subject to U.S. tax on gains from those sales, often leading to unique compliance burdens and tax implications…

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The U.S. international tax regime presents complex challenges for non-U.S. persons investing or operating in the U.S., particularly under the Controlled Foreign Corporation (CFC) rules and the intricate landscape of ownership attribution. For U.S.-based investors or multinational corporations, changes under the Tax Cuts and Jobs Act (TCJA) expanded the attribution rules and introduced new compliance…

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Choosing the right structure isn’t just important when starting your business- it’s essential to reassess periodically as your company grows. The wrong business structure could be costing you thousands in taxes, exposing you to liability, and limiting your opportunities for growth. For example, as your company evolves, changing your entity type or making a strategic…

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Looking to fund your startup? As startups grow and seek early funding, one of the most popular tools to secure capital has been the SAFE (Simple Agreement for Future Equity) note. SAFE notes were created by Y Combinator in 2013 as a more straightforward, founder-friendly alternative to convertible notes. They provide early investors the right…

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For U.S. taxpayers, earning income abroad comes with a unique challenge: the risk of double taxation. Because the U.S. taxes its citizens and residents on worldwide income—regardless of where that income is sourced—U.S. taxpayers earning money abroad could face taxes both in the foreign country where the income is earned and in the United States.…

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