Mel Whitney
Articles
IRS Notice 2025-72: What the end of the one-month deferral rule means for foreign companies
If your group has been using a one-month deferral for foreign subsidiaries, the clock just ran out. ...
FBAR vs. FATCA for US expats: Key differences, filing rules, and when you need both
FBAR and FATCA are two separate US foreign asset reporting regimes. FBAR is fi...
FBAR quiet disclosure: IRS risks, penalties, and safer options
FBAR quiet disclosure is not an official IRS compliance program. It usually me...
Capital gains tax on foreign property: US reporting, exclusions, and how to reduce tax
US citizens and resident aliens generally report ...
How to report foreign assets to IRS: Form 8938 vs 3520 vs 5471 vs 8865
US citizens and green card holders living abroad may need to file up to eight separate IRS and Treasury forms each year to report foreign assets held offshore, including accounts, entities, trusts, and gifts. Foreign asse...
Form 5471 Schedule J: Accumulated E&P and PTEP reporting guide for US shareholders
Schedule J of Form 5471 tracks the accumulated earnings and profits – known as E&P – of a controlled foreign corporation, or CFC. Schedule J is sometimes referenced as Form 5471 Sch J in IRS correspondence and practitioner shorthand. It separates previously taxed earnings and profits, referred to as PTEP, from non-previously taxed...