Andrew Coleman

A foreign owned single member LLC is one of the most common US business structures used by non-resident investors and entrepreneurs, and also one of the most misunderstood at tax time. A foreign single member LLC is simple to form, but the IRS reporting rules that apply once a foreign person owns it are strict; the penalties for missing them are ...

Form 1120-F is the US income tax return for a foreign corporation with specified US activity or income. For a 2025 calendar-year filer, the main 2026 deadline is April 15 with a US office or June 15 without one. Missing a timely return can cost ECI deductions. File Form 1120-F when a foreign corporation has a US trade or business, certa...

The GILTI tax – Global Intangible Low-Taxed Income – is a US minimum tax on the active earnings of foreign corporations controlled by US shareholders. The One Big Beautiful Bill Act renamed GILTI to “net CFC tested income” (NCTI) for tax years beginning after December 31, 2025, broadened the taxable base, and rai...

Form W-8IMY is the IRS certificate that foreign intermediaries, flow-through entities, and certain US branches use to document their status and pass along beneficial owner information to withholding agents. If your entity receives US-source income on behalf of others, this is the form that tells the withholding agent who stands behind t...

The IRS tax amnesty program — often called the tax amnesty program or federal tax amnesty — is an umbrella term for several tax compliance relief options in the US. ...

For the 2025 tax year, qualifying US taxpayers can use Form 2555 to exclude up to $130,000 of income earned from services performed abroad. The return is generally filed in 2026, and eligibility requires a foreign tax home plus either the Physical Presence Test or the Bona Fide Residence Test. The 2026 tax-year limit is...