I have a large seller note — what are the section 453A interest charge and pledge rule?
I sold a US business and I'm carrying a big seller note. Someone mentioned a section 453A 'interest charge' and a 'pledge rule' if I borrow against the note. When do those kick in, and what happens if I take a loan secured by the note?
Related Questions
What interest rate do I have to charge on a loan from me (the foreign owner) to my US LLC?
I wired money into my US LLC to fund operations and we're calling it an owner loan. What interest rate keeps the IRS happy under the section 482 rules? Is there a safe range tied to the AFR I can just...
I'm selling my US rental on a payment plan — can I spread the tax with the installment method?
I'm a non-resident and I'm selling a US rental property to a buyer who'll pay me over five years. Can I use the installment method so I only pay US tax on the gain as the payments come in, instead of ...
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...
How much underpayment interest does the IRS charge a foreign-owned LLC that paid corporate tax late in 2026?
My foreign-owned Delaware C-corp underpaid its 2025 estimated tax and now owes a balance after filing the 1120. The IRS notice mentions interest in addition to the penalty. I want to understand the ra...
Does the FIRPTA buyer really withhold 15% of the whole price at the first payment?
I'm selling US real estate to a US buyer on installments. My buyer's attorney says they have to withhold 15% of the entire sale price out of the first payment, but my down payment is small and that wi...
How is the gross-profit percentage on Form 6252 actually calculated?
I keep reading about a 'gross-profit ratio' on the installment sale. How do I actually compute it, and how does the mortgage the buyer is assuming affect it? I want to estimate how much of each paymen...
Selling my property LLC with 20% down and four annual payments — buyer says all the FIRPTA tax is withheld NOW?
I'm a foreign seller. My disregarded LLC holds a US commercial property, and the buyer and I agreed on an installment deal: 20% at closing, the rest over four years. I expected tax (and withholding) t...
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...
Does my foreign LLC need to worry about the $10,000 cash transaction reporting rule?
I've read that banks are required to report cash transactions over $10,000. My foreign LLC occasionally receives large client payments — sometimes $15,000-$20,000 at a time via ACH or wire transfer. ...
Why does one 'membership interest sale' have three possible US tax outcomes?
I'm negotiating to sell my stake in a US LLC, and every adviser answers my tax questions with 'it depends on the classification.' The contract is a standard membership-interest purchase agreement eith...
Have a similar question?
ForeignLLCTax members get expert answers with IRS citations. One CPA consultation costs $200+. Full access is $9.99/month.
Become a Member — $9.99/moDisclaimer: All content on ForeignLLCTax.com is created by a tax professional and is provided for general educational and informational purposes only. It does not constitute tax, legal, or accounting advice, and should not be relied upon as such. Every tax situation is different — for advice specific to your circumstances, please consult a licensed CPA, Enrolled Agent, or tax attorney. By using this website, purchasing a subscription, or accessing any tools or services, you acknowledge that no client-professional relationship is established between you and ForeignLLCTax.com or its operators. This website is not affiliated with the IRS.
