Real Tax Questions, Expert Answers
Get answers to your foreign-owned LLC tax questions from ForeignLLCTax. Every answer includes IRS source citations and step-by-step guidance.
If the IRS adjusts my related-party pricing, how big are the section 6662 transfer pricing penalties — 20% or 40%?
I want to understand the downside before it happens. If the IRS decides my intercompany prices were off and makes a section 482 adjustment, what penalty am I looking at? I see both 20% and 40% mention...
Did the IRS accept my Form 8832? I got a notice and I'm working from a Spanish 'Formulario 8832'
I filed to change my LLC's classification and received an IRS notice, but I'm not sure if it means accepted or rejected. I prepared everything from a Spanish 'Formulario 8832' I found online. Is there...
What's the Form 706-NA deadline, and what are the spouse and charity traps?
If a nonresident with US assets dies, how long does the executor have to file Form 706-NA, and can you get an extension? I also want to know about two things I've heard are traps: leaving US assets to...
Can I keep my section 6038A records electronically, or do I need paper? Is a folder of PDFs enough?
I run everything paperless. My invoices, contracts, and bank records are all scanned into cloud folders, and my accounting is in software. Is electronic storage actually acceptable for section 6038A, ...
Stripe sent my LLC a 1099-K and YouTube sent a 1042-S — how do I reconcile two different forms?
My foreign-owned US LLC got a 1099-K from Stripe (for sponsor and membership payments routed through it) and separately a 1042-S from YouTube for US-viewer withholding. They show different numbers and...
Do I need to follow Section 263A UNICAP rules for my foreign-owned LLC selling on Amazon?
I'm a Singapore resident running a foreign-owned Wyoming LLC that sells supplements on Amazon FBA. My accountant brought up 'Section 263A UNICAP' and said it might require capitalizing freight, wareho...
How do foreign partners track outside basis in a U.S. LLC partnership — does LLC debt count?
I'm a foreign partner with a 30% interest in a multi-member U.S. LLC taxed as a partnership. The LLC took out a $500,000 nonrecourse bank loan to buy equipment. My CPA mentioned 'outside basis' affect...
On Form W-8BEN-E Part III, what's the difference between line 14a, 14b, and 15? My U.S. payor keeps rejecting my form.
I'm a UK-incorporated Ltd company providing software licensing services to a U.S. tech firm. They're withholding 30% on my royalty payments unless I get my W-8BEN-E approved. I checked 14a 'resident o...
What goes on Form 5472 Part V — and when do I actually have to fill it out?
I'm filing Form 5472 for my Wyoming LLC for the 2026 tax year. Parts IV (monetary) and VI (Items Affecting Foreign Owner) I sort of understand, but Part V is confusing — the heading says 'Reportable T...
I'm based in Dubai and own a Wyoming LLC — does UAE's 9% corporate tax apply to my U.S. LLC profits?
I moved to Dubai in 2023 and run a consulting business through a Wyoming single-member LLC. I just heard that UAE introduced 9% corporate tax effective 2023 and there's something about a 'substance te...
I'm a Taiwan resident with a U.S. LLC — does Taiwan tax me on undistributed LLC earnings under the new CFC rules?
I'm a Taiwanese tax resident running a U.S. software LLC (single-member, disregarded for U.S. tax). I just learned Taiwan rolled out CFC rules effective 2023 and I'm worried that even if I leave profi...
Can the IRS get my passport revoked if my Wyoming LLC owes back tax?
I'm a Mexican citizen with a Wyoming LLC. The LLC has unpaid Form 5472 penalties from 2023 and 2024 totaling around $50,000. I just renewed my Mexican passport and I'm planning to visit the U.S. for a...
What's the minimum interest rate I need to charge my Wyoming LLC on a 2026 owner loan?
I want to lend $80,000 from my personal account in Germany to my foreign-owned single-member Wyoming LLC for a 3-year term. I know there's some IRS minimum interest rate I have to charge or there's an...
After I mail a Streamlined package, does the IRS confirm it accepted my submission?
I'm about to send my Streamlined package. Will I get a letter back saying I'm in the clear? How long does it take, and can they still audit me afterward?
Can I use First-Time Abatement on my Form 5472 penalty? My CPA says no but I see the FTA program on irs.gov.
I got a $25,000 Form 5472 penalty for one late tax year. My filing history is otherwise clean — no prior penalties. My CPA says First-Time Abatement doesn't apply to Form 5472, but the FTA page on irs...
Form 8938 for my foreign-owned LLC — when is the LLC a 'specified domestic entity' and what are the penalties?
My foreign owner uses a Wyoming LLC to hold a brokerage account in Switzerland. We've been filing the LLC's Form 5472 and the owner's FBAR. Someone said the LLC itself might also have a Form 8938 obli...
What are the current 2025 FBAR penalty ceilings — and does the 50% rule still apply?
I see different FBAR penalty numbers in different sources. Some say $10,000 non-willful and $100,000 willful — but those look like the original 1970 statutory caps. What are the current 2025/2026 infl...
PRN 711 vs PRN 625 on my Form 5472 penalty notice — why does the code matter?
I received a CP215 notice with a Penalty Reference Number 711. My CPA mentioned PRN 625 might apply too. What's the difference between PRN 711 and PRN 625 on Form 5472 penalties, and does the code aff...
Boyd v. United States — was the Ninth Circuit's 2021 ruling the precedent that led to Bittner?
I read that Boyd was the pre-Bittner case that held the same per-report rule. My case is in California (Ninth Circuit). Does Boyd give me any additional argument beyond what Bittner already provides?
What did the 11th Circuit do to the CTA in December 2025, and what bills are pending?
I heard the 11th Circuit ruled on the CTA in December 2025 — does that mean BOI reporting is coming back? Also are there any active bills in Congress that could change things either way?
I'm exempt from BOI now but want to be ready if it returns — what records should I keep?
My Delaware LLC is exempt under the March 2025 IFR but I'd hate to scramble if the rule gets reversed. What's a minimal set of records I should keep on hand so I can file within 30 days if BOI reporti...
If BOI reporting comes back for US-formed LLCs, what are the actual penalties?
I'm currently exempt under the March 2025 IFR but I want to plan for the possibility it gets reversed. What does the underlying statute say about BOI penalties — civil and criminal — and is there any ...
I'm a US citizen and 30% owner of a UK company that registered in California. Do I report my BOI?
My UK Ltd company foreign-qualified in California for some business activities. I'm a US citizen and own 30% of the UK company. The UK company is a foreign reporting company under FinCEN. Do I persona...
FinCEN's February 2026 CDD relief — does it help me open additional accounts?
I read that FinCEN gave banks relief in February 2026 from re-collecting beneficial-ownership data at every new account opening. I already have a Mercury account and want to open a Relay account in th...
Wise Business 40-currency native vs Mercury/Relay USD-only — which fits which use case?
My foreign-owned LLC collects payments from US, UK, and EU customers. I'm comparing Wise Business, Mercury, and Relay. Wise advertises 40+ currency balances; Mercury and Relay seem USD-centric. What's...
Grasshopper Bank for foreign-owned LLCs — is it really US-citizen-only?
Grasshopper Bank keeps appearing in 'best fintech for startups' lists and looks great on paper. I tried to apply for my Wyoming LLC and got declined with no clear reason. A friend says Grasshopper act...
Bank of America for nonresident business owners in 2026 — what's the actual status?
Different blogs say different things about Bank of America for foreign-owned LLCs. Some say they accept nonresidents at branches; others say they require US residency. I tried to read BofA's own pages...
Wells Fargo for foreign-owned LLCs — is it true every signer needs an SSN?
I have an EIN for my Wyoming LLC but no personal SSN. I read that Wells Fargo opens business accounts in branches, so I was planning to fly to the US. A relative said Wells requires an SSN from EVERY ...
How long do I have to keep my foreign-owned LLC's records — is there a fixed number of years?
I want to clean up old files but I'm afraid of throwing out something the IRS will want. Is there a set retention period for section 6038A records, like seven years? My situation is messy because some...
Can I use the installment method when I sell my interest in a US partnership/LLC?
I'm a foreign partner selling my interest in a US LLC taxed as a partnership, with the price paid over three years. Can I report on the installment method, and is there any withholding on the sale lik...
Have a tax question?
ForeignLLCTax members can submit questions and get expert answers with IRS source citations. Join the community for $9.99/month.