Mel Whitney

If your group has been using a one-month deferral for foreign subsidiaries, the clock just ran out. ...

US citizens and resident aliens generally report ...

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...

To change state residence, focus on 5 core goals: choose a new domicile, establish real ties there, end key ties to the old state, update your records, and complete any required state tax filings. The detailed process below breaks those goals into 7 coordinated actions. A state-residency change before an overseas move is a state-law iss...

Form W-8ECI is the IRS certificate a foreign person files to certify that their US-source income is effectively connected with a US trade or business – allowing that income to be taxed at regular graduated rates instead of the flat 30% FDAP withholding rate. Under IRC Section 864(c), income qualifies as effectivel...

Form W-8BEN-E is the IRS certificate used by foreign entities to establish their status as beneficial owners of US-source income and to claim reduced withholding rates under a tax treaty or FATCA exemption. The IRS W-...