What it is
The reporting that attaches when money, accounts, property, a company or a family member sits outside the United States. It is its own body of rules, and many of its penalties are fixed amounts per form, owed even when no tax is due.
Who needs it
- A U.S. person holding foreign bank or investment accounts
- A U.S. person (citizen, green-card holder or resident) who owns property abroad and rents it out
- Anyone who owns part of a company registered outside the United States
- Someone who received a large gift or inheritance from family abroad
- A visa holder working out whether they have become a U.S. tax resident
- Someone applying for an ITIN from outside the country
- A green-card holder or citizen considering giving that status up
- A foreign owner of a U.S. corporation or single-member LLC
- A nonresident with U.S. income, such as rent from a U.S. property or the sale of one
What we do
- FBAR (FinCEN 114) and Form 8938 foreign account reporting
- Form 3520 for gifts or inheritances from abroad and for foreign trusts
- Form 5471 for foreign corporations, including the U.S. tax on profits kept inside a foreign company you control (GILTI, renamed NCTI from 2026)
- The substantial presence test, and treaty positions where one applies
- ITIN applications, including passport certification when you cannot travel to the U.S.
- Form 8854 and the expatriation rules for those giving up status
- Streamlined filing where returns were genuinely missed rather than hidden
- Form 5472 every year for U.S. corporations at least 25% foreign-owned and for single-member LLCs with a foreign owner
- Nonresident returns (Form 1040-NR), including rent from U.S. property and the sale of a U.S. property
What to bring
- The highest balance during the year of every account held outside the U.S.
- Ownership documents for any foreign company, and its financial statements
- For property abroad you rent out: rent received, expenses, local property tax paid, the purchase date and cost, and the account the rent is paid into (it counts toward the FBAR)
- Your entry and exit dates if residency is the question
- Any notice you have received from the IRS about foreign reporting
What happens next
Bring the situation, not a completed form. Most of the work here is deciding which forms apply before any of them is filled in.
