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.
Does Singapore's territorial tax system exempt my U.S. LLC income from Singapore tax?
I keep hearing that Singapore only taxes local income. My U.S. LLC earns all revenue from U.S. clients and the money sits in a U.S. bank account. If I do not remit the money to Singapore, do I owe zer...
Does FIRPTA treat commercial real estate differently from residential property?
I own a small strip mall in Texas through my foreign-owned LLC and I'm thinking about selling. Most of the FIRPTA information I find online talks about houses and condos. Are the rules different for c...
When should a foreign LLC owner elect C-Corp status?
I have been running my US LLC as a disregarded entity for two years now. My revenue has grown substantially and I am wondering if it makes sense to elect C-Corp status using Form 8832. At what income ...
Does storing inventory in Amazon FBA warehouses create sales tax nexus for my foreign LLC?
I run a foreign-owned LLC and use Amazon FBA. My products end up in warehouses in California, Texas, New Jersey, and a few other states I can't even track properly. Amazon moves my inventory around wi...
What is IRC 482 transfer pricing and can the IRS reallocate income between my foreign company and my U.S. LLC?
I own a software company in Ireland and a separate LLC in Delaware. My Irish company licenses software to the U.S. LLC, which sells it to U.S. customers. My CPA warned me about IRC 482 'transfer prici...
Form 8865 Category 4 Filers Explained (Ep. 47)
I have interests in a foreign partnership and need to understand: Form 8865 Category 4 Filers Explained. What are the filing thresholds and requirements?
My accountant charged me $800 for a zero-income Form 5472 filing. Is that normal?
I have a single-member LLC with literally zero transactions. My CPA charged $800 to file Form 5472 + pro forma 1120. That seems really high for what should be a simple return. What do others pay?
What are all the FIRPTA deadlines I need to know about? I keep finding different dates and I'm confused.
I'm planning to sell my investment property through my foreign-owned LLC sometime this year. I've been researching FIRPTA and there seem to be multiple deadlines — 20 days for something, 90 days for s...
Can I use the Closer Connection Exception to avoid U.S. tax residency even if I meet the Substantial Presence Test?
I own a Wyoming LLC and I spent 135 days in the U.S. this year, plus about 100 days in each of the prior two years. When I run the weighted formula, I come to about 185 days, which puts me over the 18...
Mixed-Use Vehicle Deduction: One Car for Business and Personal Use (Ep. 13)
I'm new to U.S. taxes and need to understand: Mixed-Use Vehicle Deduction: One Car for Business and Personal Use. Can someone explain this in straightforward terms?
Does Amazon moving my FBA inventory between warehouses create nexus in new states without my consent?
This might sound crazy but apparently Amazon can move my inventory to any warehouse they want without telling me. I just discovered my products were in 12 different states! I'm a foreign LLC owner fro...
What happens if my LLC had only $50 in the bank account the whole year?
My LLC literally only has $50 from the initial deposit. No revenue, no expenses beyond the registered agent fee. Do I still need to file Form 5472 for this?
What are Colorado's tax requirements for a foreign-owned LLC with Colorado sales?
I sell outdoor gear online and ship to Colorado customers. My LLC is in Wyoming and I'm a non-resident alien from Germany. Colorado sales were about $90,000 last year. I know about sales tax but are t...
What KYC/AML compliance do I need for my foreign-owned LLC's crypto exchange accounts?
I'm trying to open a Coinbase business account for my foreign-owned Wyoming LLC. They're asking for a ton of documentation — my passport, proof of address overseas, LLC formation documents, EIN letter...
Are cross-chain bridge transactions taxable events for my foreign-owned LLC?
My LLC bridges ETH from Ethereum to Arbitrum and Optimism to take advantage of lower gas fees for DeFi. I also bridge USDC between chains. When I bridge, I send ETH on one chain and receive wrapped ET...
Do I need to file Spain's Modelo 720 for my U.S. LLC and bank account?
I've heard horror stories about Spain's Modelo 720 — massive penalties for late filing. The European Court of Justice ruled the penalties were excessive. Has this changed? I have a U.S. LLC with a ban...
What is IRC 881 and when does the 30% withholding tax apply to foreign corporations with U.S. income?
My LLC elected to be taxed as a corporation using Form 8832. I'm the sole owner and I live in Singapore. My tax advisor mentioned IRC 881 and said there could be a 30% withholding tax on certain types...
I heard foreign pension funds are exempt from FIRPTA — can I use my pension to invest in U.S. real estate tax-free?
I'm a financial advisor in London and I have several clients with substantial self-invested personal pensions (SIPPs) who want to invest in U.S. real estate. Someone mentioned that "qualified foreign ...
Does the generation-skipping transfer tax apply to NRAs with U.S. LLC assets?
I want to leave my U.S. LLC directly to my grandchildren (skipping my children). I'm a non-resident alien from France. Someone mentioned that there's a 'generation-skipping transfer tax' in the U.S. t...
What is Ohio's Commercial Activity Tax and does it apply to my foreign-owned LLC?
I ship products to Ohio customers from my warehouse in Texas. My LLC is formed in Wyoming and I'm a non-resident alien from China. Last year I had about $200,000 in Ohio sales. Someone mentioned Ohio ...
Penalty abatement for Form 5472 — has anyone succeeded?
I got hit with the $25,000 penalty for not filing Form 5472 for 2024. I genuinely didn't know about the requirement. Has anyone successfully gotten this penalty reduced or removed? What was your appro...
Form 8379: Allocation Between Spouses on Joint Return (Ep. 62)
I believe I qualify as an injured spouse. I need help understanding: Form 8379: Allocation Between Spouses on Joint Return. How does the allocation process work?
How does the stepped-up basis work for inherited LLC interests from an NRA decedent?
My father was a non-resident alien who owned a 40% interest in a multi-member U.S. LLC that holds commercial real estate and stocks. He passed away recently and I'm inheriting his interest. I understa...
Can my U.S. LLC income be tax-free in both the U.S. and Hong Kong?
I run a digital services business through a U.S. LLC. I have no U.S. presence and all work is done from Hong Kong. If the U.S. does not tax me (no ECI) and Hong Kong does not tax me (offshore income),...
How do Nigerian forex restrictions affect repatriating my U.S. LLC profits?
I earn USD through my LLC but need NGN for my living expenses in Nigeria. The official exchange rate and the parallel market rate are very different. Which rate do I use for tax purposes? And can I le...
My LLC owns U.S. real estate — what is FIRPTA under IRC 897 and how does it affect me when I sell?
I'm a French citizen with a Wyoming LLC that holds a rental property in Texas. I'm thinking about selling the property next year. My real estate attorney mentioned FIRPTA and IRC 897, saying the buyer...
What is the GILTI high-tax exclusion, and how do I elect it?
My CFC is in a country with a 25% corporate tax rate. My tax advisor mentioned that there's a 'high-tax exclusion' for GILTI that could mean I don't have to include this income. How does it work? Is i...
Foreign Income Tax Overview: IRS Rules for U.S. Taxpayers (Ep. 36)
I have income from outside the U.S. and need guidance on: Foreign Income Tax Overview: IRS Rules for U.S. Taxpayers. What are my reporting obligations and how do I stay compliant?
SWIFT vs ACH: which should I use for payments as a foreign LLC owner?
I keep seeing ACH and SWIFT mentioned when talking about U.S. banking. I understand SWIFT is for international transfers and ACH is domestic, but I'm confused about when to use which. If I receive a ...
How does the mark-to-market exit tax actually work? What assets are included and what's the exclusion?
I'm a covered expatriate with a net worth around $3.5 million, including my LLC, a house in California, stock investments, and some cryptocurrency. If the IRS treats me as if I sold everything the day...
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