1,407 plain-English guides on cross-border moves, US and Canadian returns, and small-business money. Each one ends in what to do next, and says when a written Position Check is the smarter first step.
October 5, 2026
U.S. tax law lets the owner of many foreign companies choose how the U.S. treats them — as a corporation, a partnership, or as transparent. How the election works, which entities are eligible, the 75-day window, what changes when an existing company elects, and when it's the right move.
Read more →October 5, 2026
Expanding abroad means choosing between operating directly — a branch or disregarded entity — and forming a separate foreign corporation. The U.S. tax consequences differ sharply: when income is taxed, whether losses count, which forms apply, and how foreign tax is credited. The comparison, with when each fits.
Read more →October 5, 2026
A company organized outside the United States owes a U.S. return when it does business in the U.S. or earns certain U.S. income. What triggers Form 1120-F, how effectively connected income and the branch profits tax work, how treaties and permanent establishment change the answer, and why a protective return is often worth filing.
Read more →October 5, 2026
If you own a foreign company that the U.S. ignores as a separate taxpayer, or run a business abroad directly, Form 8858 is the information return that reports it. Who files, what it asks for, how it attaches to your return, and the penalty for leaving it out.
Read more →October 5, 2026
A share in a foreign partnership — a business with a local co-founder, a family firm abroad, a foreign investment fund structured as a partnership — brings Form 8865. The four filing categories, what each must report, how partnership income reaches your return, and the penalties.
Read more →October 5, 2026
The rule that taxes a controlled foreign corporation's profit to its U.S. owners every year, whether or not it's distributed — written for multinationals, applied to one-person companies abroad. How the inclusion is computed on Form 8992, why individuals are hit harder than corporations, and the elections that soften it.
Read more →October 5, 2026
Americans abroad often run their business through a local company — and acquire a second set of U.S. filings in the process. Forms 5471 and 8858, the controlled-foreign-corporation income rules, and when a foreign company is worth it anyway.
Read more →October 5, 2026
The older of the two rules that tax a foreign company's income to its U.S. owners before any dividend is paid. What counts as subpart F income — passive income and certain related-party sales and services — the exceptions that matter for small companies, and how it differs from the net CFC tested income (formerly GILTI) inclusion.
Read more →October 5, 2026
When one owner controls companies in two countries and money moves between them — management fees, shared staff, licensed software, loans — each tax authority wants the price to be what strangers would have agreed. What arm's-length pricing means for a small group, the documentation that protects you, and the penalties for guessing.
Read more →October 4, 2026
Beneficial ownership information reporting in 2026: the Corporate Transparency Act, the 2025 rule exempting domestic companies and U.S. owners, which foreign companies must still report, deadlines and penalties, the New York LLC Transparency Act, and what to do with a report already filed.
Read more →October 1, 2026
Form 5471 explained: who files it (the five filer categories), what it reports about a foreign corporation, how it connects to subpart F and GILTI, the US$10,000 penalty, and the open statute of limitations that makes a missed form costly.
Read more →October 1, 2026
Form 5472 explained: which foreign-owned U.S. corporations and single-member LLCs must file it, the reportable transactions with related parties, the pro forma Form 1120 for a disregarded LLC, and the US$25,000 penalty most foreign owners have never heard of.
Read more →October 1, 2026
The section 962 election explained: how an individual U.S. shareholder of a controlled foreign corporation can be taxed on subpart F and GILTI as if a domestic corporation — the corporate rate, the section 250 deduction, the indirect foreign tax credit — and the second tax on later distributions.
Read more →The content on this page is for informational purposes only and does not constitute professional tax, accounting, or legal advice. See our full legal disclaimer.
