Who counts as a 'beneficial owner' for BOI reporting — just me or also my spouse and business partners?
I am a South Korean citizen and I co-own a U.S. LLC with my wife (also Korean) and a Canadian business partner. We each own one-third. My wife handles the finances but is not listed on any formation documents. Our Canadian partner manages daily operations. For the BOI report, which of us are beneficial owners? Is it based on ownership percentage, control over operations, or both? Also, our attorney filed the Articles of Organization for us — does she count as a 'company applicant' that we need to report?
Can I appoint someone in the U.S. to handle my foreign-owned LLC's payroll tax filings using Form 2678?
I'm a foreign owner of a U.S. LLC and I live overseas. Managing payroll tax deposits and filing Form 941 from abroad is difficult. I heard about Form 2678 that lets you appoint a fiscal agent to handle employment tax responsibilities. How does this work? Is the fiscal agent then responsible for making deposits and filing returns? Does this reduce my personal liability? Can my CPA serve as the fiscal agent?
ISO and AMT: How Incentive Stock Options Trigger AMT
I'm worried about the Alternative Minimum Tax: ISO and AMT: How Incentive Stock Options Trigger AMT. How do I know if this affects me and what can I do about it?
What is Oregon's Corporate Activity Tax and when does it apply to a foreign-owned LLC?
I heard Oregon has a new Corporate Activity Tax (CAT) on top of its regular income tax. My LLC sells software subscriptions and some Oregon customers are signing up. My LLC is formed in Wyoming and I'm from the Netherlands. Do I need to worry about this?
What is Previously Taxed Income (PTI) and how does IRC 959 work for CFC distributions?
My CFC has been operating for several years and I've been including Subpart F and GILTI income on my U.S. tax return. Now the CFC is about to distribute a large dividend. My understanding is that I shouldn't be taxed again on income I've already paid U.S. tax on. How does the PTI exclusion work under IRC 959? And how do I track which earnings have been previously taxed?
Can a foreign LLC owner do a 1031 exchange to defer FIRPTA tax? Or does FIRPTA block it?
I own a rental duplex in Arizona through my foreign-owned SMLLC and want to sell it and buy a larger property. I've heard about 1031 exchanges where you can defer capital gains tax by reinvesting in a like-kind property. Does this work for foreign owners? If I do a 1031 exchange, does the buyer still withhold the 15% FIRPTA amount at closing? That would defeat the whole purpose since I need the full proceeds to buy the replacement property. I'm a citizen of Israel, non-resident alien.
What's the difference between a bilateral APA and a unilateral APA?
My tax advisor mentioned that if I ever need an APA, I should go bilateral rather than unilateral. But she didn't explain why. My parent company is in France and my LLC is in the U.S. If both countries have a tax treaty, does that make a bilateral APA mandatory? What's the downside of a unilateral APA?
Why the Alternative Minimum Tax Exists: A Brief History
I'm worried about the Alternative Minimum Tax: Why the Alternative Minimum Tax Exists: A Brief History. How do I know if this affects me and what can I do about it?
What is Form 8854 and when do I need to file it for expatriation?
I recently surrendered my green card at the U.S. embassy. The consular officer mentioned something about Form 8854 but didn't give me details. Is this just a one-time filing, or do I need to file it every year? What information does it require? My accountant back home has never heard of this form. I want to make sure I don't miss any deadlines.
What tax issues matter most for e-commerce and digital-service businesses selling into Japan?
I need the Japan answer for online selling and digital services, not a generic marketplace article. Please explain how ordinary consumption tax rules, platform taxation for B2C electronic services, and foreign-business compliance fit together once sales to Japanese customers start.
I gave my U.S. LLC an interest-free loan — what does IRC 7872 say about below-market loans between related parties?
I'm a French entrepreneur and I lent my Delaware LLC $200,000 at 0% interest to fund its operations. A friend who is a CPA told me this could create tax problems under IRC 7872 — something about the IRS treating it as if I charged interest even though I didn't. He said there could be 'phantom income.' Is that real? Can the IRS really tax me on interest I never charged or received?
Alternative Minimum Tax (AMT) Explained Simply
I'm worried about the Alternative Minimum Tax: Alternative Minimum Tax Explained Simply. How do I know if this affects me and what can I do about it?
How does Japan tax distributions from my U.S. LLC?
I transfer money from my U.S. LLC bank account to my Japanese personal bank account every month. My Japanese tax advisor says these are dividends from a foreign corporation and should be taxed as dividend income. But in the U.S., the LLC is disregarded — there are no 'dividends.' How should I report these transfers on my Japanese tax return?
AMT Credit: How to Recover Your Alternative Minimum Tax (Ep. 20)
I'm worried about the Alternative Minimum Tax: AMT Credit: How to Recover Your Alternative Minimum Tax. How do I know if this affects me and what can I do about it?
Common AMT Triggers: Private Activity Bonds (PABs) Explained (Ep. 19)
I'm worried about the Alternative Minimum Tax: Common AMT Triggers: Private Activity Bonds Explained. How do I know if this affects me and what can I do about it?
Common AMT Triggers: Accelerated Depreciation Explained (Ep. 18)
I'm worried about the Alternative Minimum Tax: Common AMT Triggers: Accelerated Depreciation Explained. How do I know if this affects me and what can I do about it?
Common AMT Triggers: Incentive Stock Options (ISO) Explained (Ep. 17)
I'm worried about the Alternative Minimum Tax: Common AMT Triggers: Incentive Stock Options Explained. How do I know if this affects me and what can I do about it?
Why Does the Alternative Minimum Tax Exist? History and Purpose (Ep. 16)
I'm worried about the Alternative Minimum Tax: Why Does the Alternative Minimum Tax Exist? History and Purpose. How do I know if this affects me and what can I do about it?
How does Italian CFC legislation apply to my U.S. disregarded LLC?
My Italian commercialista says my U.S. LLC triggers Italy's CFC rules because it pays no U.S. tax. He says I have to pay IRPEF on the LLC's entire income even though I left most profits in the U.S. bank account. Is there any exemption I can claim? Can the Italy-U.S. treaty help?
How does French dividend withholding and treaty relief work for non-residents?
I want the practical France treaty answer for dividends paid abroad. Please explain when treaty relief can reduce withholding at source, when a refund route is needed instead, and why 2026 matters if a treaty eliminates French withholding but the payer still deducts it first.
What Is the Alternative Minimum Tax (AMT)? Complete Explanation (Ep. 15)
I'm worried about the Alternative Minimum Tax: What Is the Alternative Minimum Tax ? Complete Explanation. How do I know if this affects me and what can I do about it?
General Business Credit Calculation Example on Form 3800
I'm trying to maximize my tax credits: General Business Credit Calculation Example on Form 3800. How do I calculate and claim these credits correctly?
How the General Business Credit Works: Form 3800 Mechanics
I'm trying to maximize my tax credits: How the General Business Credit Works: Form 3800 Mechanics. How do I calculate and claim these credits correctly?
Form 3800: Filing the General Business Credit
I'm trying to maximize my tax credits: Form 3800: Filing the General Business Credit. How do I calculate and claim these credits correctly?
General Business Credit Introduction and Overview
I'm trying to maximize my tax credits: General Business Credit Introduction and Overview. How do I calculate and claim these credits correctly?
FTC Allowed Formula: How to Calculate Your Foreign Tax Credit
I'm trying to maximize my tax credits: FTC Allowed Formula: How to Calculate Your Foreign Tax Credit. How do I calculate and claim these credits correctly?
Which Foreign Taxes Qualify for the Tax Credit?
I'm trying to maximize my tax credits: Which Foreign Taxes Qualify for the Tax Credit?. How do I calculate and claim these credits correctly?
Foreign Tax Credit: Introduction to Avoiding Double Taxation
I'm trying to maximize my tax credits: Foreign Tax Credit: Introduction to Avoiding Double Taxation. How do I calculate and claim these credits correctly?
Form 3800 Calculation Example: General Business Credit Step by Step (Ep. 27)
I'm trying to maximize my tax credits: Form 3800 Calculation Example: General Business Credit Step by Step. How do I calculate and claim these credits correctly?
What is the Trust Fund Recovery Penalty and can it hit me personally as a foreign LLC owner?
My attorney mentioned something terrifying called the Trust Fund Recovery Penalty (TFRP) related to payroll taxes. He said the IRS can go after me personally even though my LLC is supposed to protect me from personal liability. Is this true? I'm the sole owner of a foreign-owned LLC and I manage payroll. What exactly is a trust fund tax? How does the IRS decide who is personally liable? Can they reach my personal assets overseas?