How does IRC 163(j) business interest limitation affect my foreign-owned LLC that has a loan from its parent company?
I'm a UK citizen and my UK company lent $500,000 to my U.S. LLC at 6% interest. My CPA says IRC 163(j) might limit how much of that interest my LLC can deduct. She mentioned something about '30% of adjusted taxable income.' I always thought interest was fully deductible. Can you explain what this limitation is and whether it applies to intercompany loans specifically?
How is recurring subscription income taxed for my foreign-owned LLC?
I run an online membership community through my foreign-owned LLC. Members pay $29/month or $299/year for access to premium content, courses, and a private community. I'm based in Japan and the LLC is in Wyoming. I use Stripe Billing for recurring subscriptions. My MRR (monthly recurring revenue) is about $8,500, almost all from U.S. customers. I'm confused about when this income becomes taxable. Is it when the subscription starts? When the payment processes? When the customer accesses the content? And what happens with refunds and chargebacks — can I deduct those?
Who Qualifies as Injured Spouse? Form 8379 Guide (Ep. 61)
I believe I qualify as an injured spouse. I need help understanding: Who Qualifies as Injured Spouse? Form 8379 Guide. How does the allocation process work?
Form 8379: Allocation Between Spouses on Joint Return (Ep. 62)
I believe I qualify as an injured spouse. I need help understanding: Form 8379: Allocation Between Spouses on Joint Return. How does the allocation process work?
Innocent Spouse Qualification Part 1 (Ep. 63)
My spouse and I have a tax issue and I need to understand: Innocent Spouse Qualification Part 1. What relief options are available and how do I qualify?
Amazon FBA seller — do I need Form 5472?
I'm a foreign seller on Amazon FBA. Amazon handles everything — warehousing, shipping, payments. Do I still need to file Form 5472 for my US LLC even though Amazon manages all the operations?
How do I report crypto income in my LLC?
My LLC received payments in Bitcoin and Ethereum. How do I report this on Form 5472? Is crypto considered a reportable transaction?
Tax treaty between US and UK — does it affect my Form 5472?
I'm a UK citizen with a US LLC. Someone mentioned tax treaties might reduce my filing obligations. Does the US-UK tax treaty change anything about Form 5472?
IRS sent me a letter in Chinese — is this legit?
I got a letter from the IRS that's partially in Chinese about my LLC. It mentions Form 5472 and a penalty. Is this a scam or does the IRS actually send letters in other languages?
Innocent Spouse Qualification Part 2 (Ep. 64)
My spouse and I have a tax issue and I need to understand: Innocent Spouse Qualification Part 2. What relief options are available and how do I qualify?
How do I know if my LLC is a disregarded entity or a partnership?
I keep seeing these terms but I'm confused. I'm the only owner of my LLC. Does that automatically make it a disregarded entity? What if I add a partner later?
Can a foreign-owned U.S. LLC be classified as a CFC?
I'm a foreign national and I own a U.S. LLC. I've heard about CFC rules and I'm confused — isn't a CFC supposed to be a foreign corporation? My LLC is a U.S. entity. Under what circumstances could my LLC or something related to it be considered a CFC? I also own a company in my home country that does business with the LLC. Does that matter?
IRC 6015(f) Equitable Relief Part 1 (Ep. 65)
My spouse and I have a tax issue and I need to understand: IRC 6015 Equitable Relief Part 1. What relief options are available and how do I qualify?
First year with the LLC — what records should I be keeping?
I just formed my LLC this month. What records and documents should I start keeping from day one to make my Form 5472 filing easier next year?
Do I need a registered agent in every state where my foreign-owned LLC operates?
I have my LLC formed in Wyoming with a registered agent there. But I also sell to customers in California, Texas, and New York. Do I need registered agents in all of those states? What exactly does a registered agent do and how much does it cost across different states?
F-1 student FICA exemption and LLC self-employment
I am an F-1 student in my third year and I have an LLC for freelance graphic design work that I do under OPT. My W-2 employer does not withhold FICA taxes because of my F-1 status. But now my LLC is generating self-employment income as well. Do I need to pay self-employment tax (Social Security and Medicare) on my LLC income, or does the F-1 FICA exemption cover that too?
IRC 6015(f) Equitable Relief (Ep. 66)
My spouse and I have a tax issue and I need to understand: IRC 6015 Equitable Relief. What relief options are available and how do I qualify?
How do Japan's tax treaties actually affect residency, withholding and cross-border income?
I need the practical treaty answer for Japan, especially for a founder, investor or employee with income touching more than one country. Please explain why the treaty list matters, why domestic law is only the starting point, and why treaty benefits still have to be documented in the way Japan expects.
What are the tax implications when I lend money to my foreign LLC or make capital contributions?
I'm the sole foreign owner of a U.S. LLC. When I first started the LLC, I transferred $5,000 from my personal account to the LLC's Mercury account to cover initial expenses. I also plan to lend the LLC $20,000 to fund inventory purchases. What's the difference between a capital contribution and a loan for tax purposes? Does it matter which one I call it? And do I need to report these on Form 5472? Someone told me that capital contributions are reportable transactions but I'm not sure about loans.
Married filing separately — will this affect my spouse's immigration case?
My spouse is applying for a green card and we're wondering if filing separately vs jointly has any impact on the immigration process. Our tax situation makes MFS more advantageous but we don't want to jeopardize anything.
Form 8857 Introduction: What Is Innocent Spouse Relief?
My spouse and I have a tax issue and I need to understand: Form 8857 Introduction: What Is Innocent Spouse Relief?. What relief options are available and how do I qualify?
Does PayPal count as a US bank account for FBAR purposes?
I have a PayPal business account linked to my LLC. It sometimes holds significant balances. Does this count toward the $10,000 FBAR threshold?
I'm from Thailand — how does my U.S. LLC get taxed?
I'm a Thai citizen and tax resident in Bangkok. I formed a Wyoming LLC for my content creation and social media management business. I serve international clients from Thailand. Thailand uses a remittance-based tax system for foreign income — does that mean I can avoid Thai tax if I don't bring the money into Thailand?
Form 8857: When You May Qualify for Innocent Spouse Relief (Part 2)
My spouse and I have a tax issue and I need to understand: Form 8857: When You May Qualify for Innocent Spouse Relief. What relief options are available and how do I qualify?
IRC 6015(f) Equitable Relief for Innocent Spouse (Part 2)
My spouse and I have a tax issue and I need to understand: IRC 6015 Equitable Relief for Innocent Spouse. What relief options are available and how do I qualify?
Form 8857: IRC Section 6015(f) Equitable Relief Explained (Part 2)
My spouse and I have a tax issue and I need to understand: Form 8857: IRC Section 6015 Equitable Relief Explained. What relief options are available and how do I qualify?
Form 1040 Basics and Tax Preparer Info (Ep. 54)
I need help with my filing status: Form 1040 Basics and Tax Preparer Info. What are the rules and how do I determine what applies to my situation?
Single vs MFJ vs MFS Comparison (Ep. 55)
I need help with my filing status: Single vs MFJ vs MFS Comparison. What are the rules and how do I determine what applies to my situation?
MFJ: Both Spouses Must Agree (Ep. 56)
I need help with my filing status: MFJ: Both Spouses Must Agree. What are the rules and how do I determine what applies to my situation?
Filing Status After Spouse Death (Ep. 57)
I need help with my filing status: Filing Status After Spouse Death. What are the rules and how do I determine what applies to my situation?