- Exit tax planning
- International business tax
- Overseas tax obligations
- Tax compliance for expats
- Master's of Accounting, University of Kansas School of Business
Articles
Understanding Subpart F income: Complete guide for US shareholders
Subpart F income is certain income of a CFC that a US shareholder may have to include in current US taxable income even without a distribution. For the 2025 tax year, the rules still use GILTI terminology; NCTI changes ap...
Controlled foreign corporation (CFC): rules, definition, tax and reporting
A controlled foreign corporation (CFC) is a foreign corporation in which US shareholders – US persons who each own at least 10% of the vote or value – together own more than 50% of the total vote or value. If ...
Form 5471 instructions: filing requirements for US owners of foreign corporations
Form 5471 is an IRS information return that US citizens and residents file to report ownership in, control of, or an officer or director role in a foreign corporation. It is attached to your Form 1040 (or Form 1120) and ...
Form 5471 penalty: What happens if you fail to file?
The IRS imposes a $10,000 initial penalty for not filing Form 5471 per foreign corporation, per annual accounting period – regardless of whether any tax is owed (IRC §6038(b)). If the failure continues after IR...
Form 5471 categories of filers: Category 1–5 explained (2026)
The IRS sorts Form 5471 filers into five categories of filers – Categories 1 to 5, with subcategories 1a–1c and 5a–5c. Your category of filer decides whether you file at all, which schedules you complet...
GILTI tax: Global Intangible Low-Taxed Income meaning, calculation, and examples
GILTI stands for global intangible low-taxed income. Despite the name, it is not limited to intangible income – it reaches most active business profits of a controlled foreign corporation (CFC). This guide explains GILTI as it appl...