International U.S. Citizens

International tax compliance and strategy for U.S. companies with foreign operations.

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Crossing a Border Multiplies Your Filing Obligations

The moment your business operates abroad, the reporting requirements multiply. Form 5471 for controlled foreign corporations. Form 8865 for foreign partnerships. GILTI inclusions. Subpart F income. Foreign tax credits. Each carries its own rules, elections, and automatic penalties for getting it wrong. The base penalty for a late or incomplete Form 5471 is $10,000 per form per year. Most U.S. businesses expanding abroad don’t realize the scope of what’s required until they’re already exposed.

What We Handle

We build the compliance infrastructure before the exposure exists and manage it year over year:

  • Form 5471 for controlled foreign corporations
  • Form 8865 for foreign partnerships
  • GILTI and Subpart F income analysis
  • Foreign tax credit planning and optimization
  • Check-the-box entity classification elections
  • FBAR and FATCA reporting
  • Cross-border entity structuring and advisory

Whether you’re operating a subsidiary in Latin America, sourcing internationally, or managing a distributed team across multiple countries, we handle the full stack so your global operations don’t create domestic problems.

Compliance and Planning Together

Getting the structure right upfront matters. Proper entity classification and check-the-box elections determine how your foreign operations are taxed in the U.S. Getting this wrong is expensive to unwind. We analyze your structure for GILTI exposure, foreign tax credit positioning, and Subpart F inclusions so your international growth is tax-efficient, not just compliant.

What We Handle

  • Form 5471 (Controlled Foreign Corporations)
  • Form 8865 (Foreign Partnerships)
  • GILTI & Subpart F Income Planning
  • Foreign Tax Credit Optimization
  • Check-the-Box Entity Elections
  • FBAR & FATCA Reporting
  • Cross-Border Entity Structuring
  • Foreign Subsidiary Compliance
  • International Payroll Considerations