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Similar to a subpart F inclusion, “U.S. Shareholders” of CFCs include GILTI in income on an annual basis. U.S. corporations may be entitled under section 250 to a deduction of […]

There are two directions for the IRS streamlined program. These are the SFOP (Streamlined Foreign Offshore Program) and the SDOP (Streamlined Domestic Offshore Program). Both the SFOP and SDOP has

FATCA was signed into law in 2010, with an aim to levy certain taxes on U.S. citizens and entities with substantial overseas holdings and the overseas institutions that enable some

Required when there is distribution of income from a passive foreign investment company (PFICs) in which a U.S. person is a shareholder or a disposition of the shares of a

Annual Return to Report Transactions With Foreign Trusts and Receipt of Certain Foreign Gifts Usually amounts of $100,000 or more are required to be reported in a calendar year.

U.S. citizens and U.S. residents who are officers, directors, or shareholders in certain foreign corporations are responsible for IRS Form 5471 filing. Under the TCJA, rules requiring the inclusion of