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Tax relief insights from Attorney Darrin T. Mish
Most U.S. persons with foreign corporate ownership need to file Form 5471 and related forms. Here are the thresholds, the attribution rules, and the common scenarios.
The $10,000 Form 5471 penalty has multiple paths to relief: reasonable cause, disclosure programs, and procedural challenges. Here is how each one works.
Form 5471 reports U.S. ownership of foreign corporations. Five filer categories, multiple schedules, $10,000+ penalties for nonfilers. Here is the structure.
Owning a foreign company triggers a stack of U.S. forms: 5471, 8865, 8858, FBAR, 8938, 8621. Here is the full reporting picture and how to
Form 8288-B reduces FIRPTA withholding before closing. Filed late, the form usually does not help and the refund process takes over. Here is the full
Foreign sellers of U.S. real estate owe federal capital gains tax, may owe state tax, and may have prior-year rental issues to address. Here is
FIRPTA refunds require an ITIN. There is no way around it. Here is how the ITIN application works and how to coordinate it with the