I'm buying a property from a foreign-owned LLC — what are MY obligations as the buyer for FIRPTA?
I'm a U.S. citizen buying a house from someone who I think is a foreign national (they have a foreign-sounding name and the property is in a Wyoming LLC). I'm not sure if FIRPTA applies or what I need to do. My real estate agent hasn't mentioned anything about it. What are my obligations as the buyer? Can I get in trouble if I don't withhold? How do I even find out if the seller is foreign? I don't want to insult them by asking.
What is the branch profits tax under IRC 884 and how does it apply to foreign corporations?
I'm a foreign corporation doing business in the U.S. through a branch (not a subsidiary). My U.S. tax advisor mentioned something called the 'branch profits tax' in addition to regular corporate income tax. What is it, why does it exist, and how is it calculated? Can a tax treaty reduce or eliminate it?
I'm a foreign LLC owner living in the U.S. — do I owe 'nanny tax' for my household employee?
I'm a non-resident alien who owns a U.S. LLC and I recently moved to the U.S. on a work visa. I hired a housekeeper who comes twice a week and I pay her $500/week in cash. A friend told me I might owe 'nanny tax' and could get in trouble for paying her in cash. Is this related to my LLC at all? What is the household employee tax threshold? Do I need to withhold taxes from her pay? I'm already overwhelmed with my LLC's payroll obligations and now this too?
Do I need to file Spain's Modelo 720 for my U.S. LLC and bank account?
I've heard horror stories about Spain's Modelo 720 — massive penalties for late filing. The European Court of Justice ruled the penalties were excessive. Has this changed? I have a U.S. LLC with a bank account holding about $150,000. Do I need to file, and what happens if I file late?
What are composite returns and when do states require them for nonresident LLC members?
My accountant mentioned 'composite returns' as a way to simplify state tax filing for my multi-member LLC with foreign members. We have members from three different countries and the LLC operates in four states. What exactly is a composite return and which states require or allow them?
The IRS is auditing my LLC's transfer pricing — what should I expect and how do I prepare?
I received a letter from the IRS saying they want to examine my foreign-owned LLC's Form 5472 and related transfer pricing for the past two tax years. I've been paying my overseas company a service fee and a royalty, and I have some documentation but it's not very detailed. What does the IRS examination process look like for transfer pricing? What documents will they request? How do I defend my positions?
Form 6252 Calculation: How to Report Installment Sales (Ep. 35)
I'm considering an installment sale: Form 6252 Calculation: How to Report Installment Sales. How does Form 6252 work and how do I calculate the taxable gain?
I contributed cash and equipment to my foreign partnership. Do I need Schedule O of Form 8865?
I'm a U.S. person and I contributed $100,000 in cash and some computer equipment (worth about $20,000) to a foreign partnership that I'm a 40% partner in. My tax advisor mentioned Schedule O of Form 8865 but I'm not sure what triggers this requirement. Is every contribution reportable? The partnership is based in Singapore and has three other partners who are not U.S. persons.
How are crypto gains and foreign exchange accounts handled for tax in France?
I need the France answer for an individual with crypto, not a global explainer. Please explain how occasional crypto disposals are declared, when commercial activity is treated differently, and why foreign exchange accounts or wallets can create a second filing issue beyond the gain itself.
Form 6252 Introduction: Installment Sale Reporting (Ep. 34)
I'm considering an installment sale: Form 6252 Introduction: Installment Sale Reporting. How does Form 6252 work and how do I calculate the taxable gain?
QBI for REIT and PTP: Carryover Rules and Calculation
I need help with the Qualified Business Income deduction: QBI for REIT and PTP: Carryover Rules and Calculation. How does it work and what are the carryover rules?
Negative QBI Carryover: What It Means for Your Tax Return
I need help with the Qualified Business Income deduction: Negative QBI Carryover: What It Means for Your Tax Return. How does it work and what are the carryover rules?
Pass-Through Entity Basics: Understanding QBI Deduction
I need help with the Qualified Business Income deduction: Pass-Through Entity Basics: Understanding QBI Deduction. How does it work and what are the carryover rules?
QBI Deduction for REIT and PTP Income: Negative Carryover Rules (Ep. 33)
I need help with the Qualified Business Income deduction: QBI Deduction for REIT and PTP Income: Negative Carryover Rules. How does it work and what are the carryover rules?
Negative QBI Carryover: Tax Implications Explained (Ep. 32)
I need help with the Qualified Business Income deduction: Negative QBI Carryover: Tax Implications Explained. How does it work and what are the carryover rules?
How does Japanese withholding tax and treaty relief work for foreign recipients?
I need the practical Japan answer for dividends, interest, royalties or other Japan-source payments going abroad. Please explain why domestic withholding often applies first, when treaty relief can reduce it, and why timing matters if the form is not filed before the first payment date.
If I die while owning U.S. real estate through my LLC, does my family face FIRPTA AND estate tax?
Morbid question but important. I'm a 62-year-old citizen of Thailand with a rental property in Las Vegas held through a Wyoming SMLLC. My family is all in Thailand. If something happens to me, what happens tax-wise? I've heard that non-residents face U.S. estate tax on property with only a $60,000 exemption. And then when my heirs sell the property, they'd also face FIRPTA? Is there a way to structure this so my family isn't hit with both? The property is worth about $400K.
What Is a Pass-Through Entity? QBI Deduction Basics (Ep. 31)
I need help with the Qualified Business Income deduction: What Is a Pass-Through Entity? QBI Deduction Basics. How does it work and what are the carryover rules?
Section 179 Carryover: Rules for Unused Deduction Amounts
I have questions about tax deductions: Section 179 Carryover: Rules for Unused Deduction Amounts. What are the limits and rules I need to follow?
Section 179 Limits: Annual Deduction Caps and Phase-Out Thresholds
I have questions about tax deductions: Section 179 Limits: Annual Deduction Caps and Phase-Out Thresholds. What are the limits and rules I need to follow?
What Is Section 179? Business Equipment Deduction Explained
I have questions about tax deductions: What Is Section 179? Business Equipment Deduction Explained. What are the limits and rules I need to follow?
How do Russian currency controls affect my U.S. LLC operations?
I have a U.S. LLC with a U.S. bank account. Russia requires me to report foreign bank accounts and there are rules about repatriating foreign currency earnings. What exactly do I need to report to the Russian tax authorities about my LLC's U.S. bank account? Are there penalties for non-compliance?
Section 179 Carryover Rule: What Happens to Unused Deductions (Ep. 30)
I have questions about tax deductions: Section 179 Carryover Rule: What Happens to Unused Deductions. What are the limits and rules I need to follow?
Section 179 Deduction Limits: Maximum Deduction and Phase-Out Rules (Ep. 29)
I have questions about tax deductions: Section 179 Deduction Limits: Maximum Deduction and Phase-Out Rules. What are the limits and rules I need to follow?
Why do foreign withholding agents keep asking for a certificate of residence even when the treaty article already looks clear?
I keep hearing that the treaty should be enough on its own. Please explain what a certificate of residence actually proves, why tax authorities still ask for it, and why it still does not replace the rest of the treaty analysis.
Section 179 Deduction: What Is It and How Does It Work? (Ep. 28)
I have questions about tax deductions: Section 179 Deduction: What Is It and How Does It Work?. What are the limits and rules I need to follow?
AMT Credit Carryforward: Recovering Alternative Minimum Tax Paid
I'm worried about the Alternative Minimum Tax: AMT Credit Carryforward: Recovering Alternative Minimum Tax Paid. How do I know if this affects me and what can I do about it?
Private Activity Bonds and AMT: What Investors Need to Know
I'm worried about the Alternative Minimum Tax: Private Activity Bonds and AMT: What Investors Need to Know. How do I know if this affects me and what can I do about it?
Accelerated Depreciation and AMT: Common AMT Trigger
I'm worried about the Alternative Minimum Tax: Accelerated Depreciation and AMT: Common AMT Trigger. How do I know if this affects me and what can I do about it?
Can I get a virtual debit card for my foreign LLC without a U.S. address?
I need a virtual debit card for my foreign-owned LLC to pay for online services like hosting, software subscriptions, and Google/Facebook ads. I have a Mercury account but I'm not sure if I can get a debit card shipped to my foreign address. Are virtual debit cards available immediately? Can I use them for all types of online purchases? And are there better options than Mercury's card for a foreign LLC owner who mainly needs to pay for digital services?