U.S. International Tax · Tax Treaties · IRS Code
We help foreign companies form a U.S. subsidiary, structure it for the lowest treaty-aware tax, and run the finance and agency work after launch. We also handle U.S. returns for Americans living abroad.
Consultations in English & Korean · 영어·한국어 상담 가능
For individuals · never filed abroad
The Streamlined Foreign Offshore Procedures (SFOP) let eligible non-willful Americans abroad get fully compliant — with the IRS offshore penalty waived to $0. It's the cleanest amnesty window open today, and it won't stay open forever.
See how SFOP works →✓ All of this for one flat fee — no additional costs during filing.
For foreign companies entering the U.S.
A Korean, UK, Australian, or New Zealand parent company opening a U.S. arm faces two systems at once. We set it up correctly the first time and stay on as your finance and compliance desk.
Entity choice, state of incorporation, EIN, registered agent, and the federal elections (incl. Form 5472 / treaty positions) that a foreign-owned company must get right from day one.
We don't file your forms and disappear. We sit in the founder's seat with you — cap table, books, and operating setup — so you can focus on the product, not the paperwork.
Bookkeeping, payroll, vendor payments, cash-flow runway, and board-ready reporting — the finance function a young company needs before a full-time hire makes sense.
We stand between you and the IRS, the Franchise Tax Board, the Secretary of State, and the EDD — a safe, correct setup on day one, and no costly miscommunication with agencies later.
The periodic filings that quietly lapse and trigger penalties: business-license and registration renewals, Statements of Information, registered-agent upkeep, and franchise-tax minimums — kept on a calendar we own.
Intercompany pricing, the parent's U.S. reporting exposure, withholding on dividends and royalties, and the treaty article that lowers each rate — coordinated with your home-country filing.
Which entity is right for a foreign owner?
A separate taxable entity. Pays 21% federal corporate tax; profits are taxed again when paid out as dividends. No limit on foreign shareholders, and it's the structure U.S. investors expect.
✓ Usual fit for a foreign parentPass-through — profit flows to owners and is taxed once. But every shareholder must be a U.S. citizen or resident; non-resident aliens and foreign companies cannot own an S-Corp.
✕ Not available to foreign ownersFlexible — pass-through by default, or it can elect corporate tax. A foreign-owned single-member LLC carries a Form 5472 duty and can pull the foreign owner into U.S. filing through effectively connected income.
~ Useful in specific casesFor most foreign companies opening a U.S. subsidiary, the C-Corp is the cleanest path — foreign ownership is unrestricted, the parent stays out of U.S. personal returns, and it's what investors expect. But the right answer turns on your ownership, funding plan, and home-country treaty. We model the tax outcome both ways before you sign the formation papers.
For U.S. citizens & green-card holders abroad
U.S. citizens and green-card holders file no matter where they live. We keep you compliant and claim every exclusion, credit, and treaty position you're entitled to.
Foreign Earned Income Exclusion and Foreign Tax Credit, optimized so you don't pay twice on the same income.
Foreign account and asset reporting done right — the filings with the steepest penalties when they're missed.
Behind on filing? The Streamlined Foreign Offshore Procedures let many expats catch up penalty-free. We assess eligibility and prepare the package.
Totalization Agreement analysis so freelancers and founders aren't charged Social Security tax by two countries at once.
Own a foreign corporation, partnership, or pooled fund? Forms 5471, 8865, and 8621 (PFIC) handled — including mark-to-market and excess-distribution analysis.
A foreign gift or inheritance is generally NOT taxed by the U.S. — there's no gift tax on you as the recipient. But it must be reported on Form 3520 once it crosses a threshold: more than $100,000 from a foreign individual or estate (inheritances included), or more than $20,573 (2026) from a foreign corporation or partnership. It's an information return, yet missing it carries a penalty of 5% per month, up to 25% of the gift.
Giving up U.S. citizenship or a green card
Expatriation isn't just paperwork. U.S. citizens — and long-term green-card holders who held the card in 8 of the last 15 years — must file Form 8854 to leave the U.S. tax system. If you're a "covered expatriate," the §877A exit tax treats your worldwide assets as sold the day before you go. We model it first.
You're a "covered expatriate" if any one is true: net worth of $2M+, 5-year average income tax over $211,000 (2026), or you can't certify 5 years of compliance. If covered, §877A deems your worldwide assets sold the day before expatriation, with gain above the $910,000 (2026) exclusion taxed. Retirement accounts and deferred comp follow special rules.
Many people don't realize a green card triggers the exit tax. Hold it in 8 of the last 15 years and you're a "long-term resident" subject to the same rules as a citizen. Simply letting the card lapse, moving abroad, or claiming treaty non-residency can itself be an expatriating act — so the timing of your departure matters.
Skip Form 8854 and you're automatically treated as a covered expatriate — regardless of your net worth — plus a $10,000 penalty and indefinite U.S. filing obligations. And under §2801, gifts or bequests a covered expatriate later makes to U.S. persons are hit with a transfer tax for life. Clean exits are worth doing right.
For non-residents with U.S. income or a U.S. business
A non-resident alien files Form 1040-NR. What matters is how each income type is treated — business income (ECI) at graduated rates, passive income (FDAP) at a flat rate — and where a tax treaty reduces or removes the U.S. tax. We sort the categories and claim the treaty position.
A non-resident running a U.S. trade or business — as a sole proprietor, freelancer, or single-member LLC — files Form 1040-NR. Income effectively connected to that business (ECI) is taxed at the same graduated rates as U.S. persons, on a net basis after deductions. We handle the ITIN (Form W-7), the treaty and permanent-establishment analysis, and the good news that non-residents generally owe no U.S. self-employment tax.
State residency exits and non-resident returns (1040-NR) for foreign nationals with U.S.-source income — taxed only on what the treaty allows, with the right state filings alongside the federal.
Passive U.S. income for non-residents · FDAP
FDAP — Fixed, Determinable, Annual, or Periodical income — is a non-resident's passive U.S.-source income: dividends, interest, rents, and royalties. Unlike business income (ECI), it's taxed on the gross amount with no deductions, usually withheld at the source and reported to you on Form 1042-S, then reconciled on Schedule NEC of Form 1040-NR. The right exemption or treaty article can cut the rate to 15%, 10%, or zero.
A flat 30% on the gross amount — no deductions, unlike ECI's net, graduated tax. The payer normally withholds it at the source and issues Form 1042-S; you reconcile on Schedule NEC. If too much was withheld, the return is how you claim it back.
Much U.S.-source interest escapes the tax: qualifying portfolio interest (§871(h)) and interest on U.S. bank deposits (§871(i)) generally are not taxed for a non-resident. The exceptions matter — interest that's effectively connected, or from a related party, may not qualify.
U.S.-source dividends are reportable and taxed at 30%, but a treaty usually lowers it — commonly to 15% for portfolio dividends, and sometimes 5% for large corporate holdings. We confirm the article and the paperwork (W-8BEN) so the reduced rate actually applies.
A non-resident is generally exempt from U.S. tax on capital gains — with two key exceptions: being present in the U.S. 183 days or more in the year, or gain from U.S. real property, which FIRPTA taxes and subjects to withholding. We flag which one applies before you sell.
Behind on filing? There is a way back.
If you didn't know you had to file U.S. returns, FBAR, or FATCA while living or banking abroad, the IRS Streamlined Filing Compliance Procedures let non-willful taxpayers catch up — often with reduced penalties or none at all. The catch: you must come forward before the IRS contacts you, and the program won't last forever.
For non-willful taxpayers abroad. File the last 3 years of returns and 6 years of FBAR, certify non-willful conduct — and FBAR, FATCA (8938), and Form 5471 penalties are waived entirely. You still pay any tax due plus interest, but after the FEIE and foreign tax credits many owe little or nothing.
For non-willful U.S. residents who already filed timely returns but missed foreign reporting. Amend 3 years and file 6 years of FBAR; in place of stacked FBAR and 8938 penalties you pay a single 5% on the highest year-end value of the unreported foreign assets.
The U.S. taxes by status, not by where you live. If you fall into one of these groups, the obligation follows you abroad — even if you owe no tax.
Including dual citizens and "accidental Americans" born in the U.S. — the duty applies no matter where you now live or earn.
Lawful permanent residents file as U.S. taxpayers even while living abroad — the obligation continues until the green card is formally given up.
Non-citizens who spend enough days in the U.S. are treated as resident taxpayers under the substantial-presence test — and pick up the same filings.
What triggers each filing
| Filing | Who it's for | Penalty if missed |
|---|---|---|
| FBAR FinCEN 114 |
U.S. persons with foreign accounts over $10,000 combined | Non-willful: up to $16,536 per year. Willful: the greater of $165,353 or 50% of the account balance. |
| FATCA Form 8938 |
Specified foreign financial assets above the threshold | $10,000, rising to $50,000 if not corrected after IRS notice. |
| Form 5471 | U.S. person owning 10%+ of a foreign corporation | $10,000 per form, per year — plus continuation penalties up to a $60,000 maximum per form. |
| Form 5472 | 25% foreign-owned U.S. corporation or foreign-owned LLC | $25,000 per form, per year — with continuation penalties and no statutory maximum. |
| Form 3520 3520-A |
Large foreign gifts/inheritances, and foreign trusts (incl. some foreign pensions) | Foreign gifts/inheritances: 5% per month, up to 25% of the amount. Foreign trust transfers or distributions: the greater of $10,000 or 35% of the value. |
| Form 8865 | U.S. person who owns or controls a foreign partnership | $10,000 per form, per year (up to $60,000) — plus 10% of the value of unreported property contributed, capped at $100,000. |
| PFIC Form 8621 |
Owners of foreign mutual funds, ETFs, and pooled funds | No fixed dollar penalty, but the punitive §1291 regime taxes gains at the top rate with an interest charge — and the statute of limitations on your entire return stays open until you file. |
| Form 8854 §877A |
Anyone renouncing U.S. citizenship or giving up a long-term green card | $10,000 for failing to file — and missing it automatically makes you a "covered expatriate," exposing your worldwide assets to the §877A exit tax (gain above the $910,000 (2026) exclusion). |
FBAR amounts are inflation-adjusted annually; figures shown are 2026 maximums. Penalties depend on your specific facts and whether conduct was willful — most non-willful taxpayers who come forward voluntarily reduce or eliminate them.
This is the key opportunity: for eligible non-willful taxpayers living abroad, the Streamlined Foreign Offshore Procedures waive all of these offshore penalties entirely — FBAR, FATCA, Form 5471, 5472, 3520, and 8865. You file 3 years of returns and 6 years of FBAR, certify non-willful conduct on Form 14653, and pay only any tax actually due plus interest — after the FEIE and foreign tax credits, often little or nothing. The catch is timing: the waiver is only available if you come forward before the IRS contacts you, and the program will not stay open indefinitely.
A "passive foreign investment company" is, in practice, almost any non-U.S. pooled fund. Each one needs its own Form 8621 every year — and under the default rules, gains are taxed at the highest rate with an interest charge layered on top. Many Korean investors hold these without realizing they're PFICs.
Rule of thumb: if the fund's ISIN starts with "KR," treat it as a PFIC until proven otherwise. A wrapper like an ISA or pension account doesn't make the underlying fund exempt.
How a U.S. launch works with us
We map ownership, pick the entity and state, and model the tax both ways against your home-country treaty.
Incorporation, EIN, registered agent, bank-ready documents, and the federal elections a foreign-owned entity needs.
Fractional CFO from day one — books, payroll, vendor payments, and reporting your board and parent can read.
We hold the line with U.S. agencies and keep every recurring renewal and filing on schedule, year after year.
Treaties & the Internal Revenue Code
We don't guess at cross-border tax. We cite the specific treaty article and IRS Code section behind each position — so it holds up under examination.
Reduced rates on dividends, interest, and royalties between a U.S. sub and its foreign parent — claimed correctly so the lower treaty rate actually applies.
Whether your activity creates a U.S. taxable presence — the PE analysis that decides if the parent itself owes U.S. tax.
Foreign tax credit baskets and re-sourcing, so income taxed abroad isn't taxed again in the U.S. beyond what the Code allows.
Avoiding double tax for Americans abroad
The U.S. taxes citizens on worldwide income, but two tools keep you from paying twice on income you already earned — or were taxed on — abroad. Which one saves more depends almost entirely on your host country's tax rate.
Lets you simply leave foreign earned income out of your U.S. tax — up to $132,900 per person for 2026. Only earned income qualifies (wages and self-employment) — not dividends, interest, or rentals. You must pass the 330-day physical-presence test or the bona-fide-residence test. Best when you live in a low- or no-tax country, where there's no foreign tax to credit.
Gives a dollar-for-dollar credit for income tax you actually paid abroad, against your U.S. tax on the same income. No dollar cap, it covers earned and passive income, and unused credit carries forward up to 10 years. Best when you live in a high-tax country, where foreign tax often erases the U.S. bill and even banks excess credit for later.
Rule of thumb: in a low- or no-tax country — Qatar, Monaco, the Cayman Islands — the FEIE is your tool, since there's no foreign tax to credit. In a high-tax country — the UK, Germany, Korea — the FTC usually does more, erasing your U.S. tax and building a carryforward. You can even combine them (FEIE on earned income up to the cap, FTC on the rest) — but never both on the same dollar. One caution: revoke the FEIE and you're locked out of it for 5 years, so we model the choice before you file.
Start the conversation
Tell us where your company or your filing stands. Send a short inquiry and we'll reply by email — we'll map the situation, flag anything urgent, and give you a flat-fee quote before you commit.
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