PILOT
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AI-assisted US international tax compliance

US International Tax Forms
Know What to File, and Prove Why

Import the facts and get an audit-ready answer for your clients’ international filing obligations.
PILOT (Pro International Filing Obligation Tracker) does the analysis and report, so you can focus on creating value for your client.

Start free — first 8 entities on us See a real engagement
Watch one entity become a defensible filing
Backed by the Code
Fact sheet · Atlas Trading GmbH
  • 80% — Meridian Holdings LLC (US partnership)
  • 20% — German resident
  • Entity type — GmbH
  • Jurisdiction — Germany
  • No Form 8832 on file
  • Incorporated 2019
  • Mid-year capital contribution
  • Foreign accounts > $10,000
M1Data Ingestion
builds on  Your uploads
PILOT’s reasoning

Determines→Fact sheet + org chart
Fact sheet · Atlas Trading GmbH
  • 80% — Meridian Holdings LLC (US partnership)
  • 20% — German resident
  • Entity type — GmbH
  • Jurisdiction — Germany
  • No Form 8832 on file
  • Incorporated 2019
  • Mid-year capital contribution
  • Foreign accounts > $10,000
M2Entity Classification
builds on  Atlas Trading GmbH
Authorities consulted
Treas. Reg. § 301.7701-2(b)(8) — Per Se ListTreas. Reg. § 301.7701-3 — Default classification
PILOT’s reasoning

A GmbH isn't on the per-se list (that's the public stock-corp form, e.g. an AG). No Form 8832 on file → an unconfirmed election is a risk flag, not an election. Default rule for a foreign eligible entity with limited liability → association taxable as a corporation.

Determines→Classification: Corporation
Fact sheet · Atlas Trading GmbH
  • 80% — Meridian Holdings LLC (US partnership)
  • 20% — German resident
  • Entity type — GmbH
  • Jurisdiction — Germany
  • No Form 8832 on file
  • Incorporated 2019
  • Mid-year capital contribution
  • Foreign accounts > $10,000
M3Ownership Attribution
builds on  Atlas = Corporation
Authorities consulted
IRC § 958 — Rules for determining stock ownershipIRC § 318 — Constructive ownership of stock
PILOT’s reasoning

Meridian Holdings LLC — a US partnership — holds 80% of Atlas directly. Applied the § 958(a) direct and indirect ownership rules and § 318 constructive attribution, with § 958(b)(4) treated as repealed (post-TCJA).

Determines→Layered US ownership
Fact sheet · Atlas Trading GmbH
  • 80% — Meridian Holdings LLC (US partnership)
  • 20% — German resident
  • Entity type — GmbH
  • Jurisdiction — Germany
  • No Form 8832 on file
  • Incorporated 2019
  • Mid-year capital contribution
  • Foreign accounts > $10,000
M4Status Determination
builds on  Layered US ownership
Authorities consulted
IRC § 957 — Controlled foreign corporationsIRC § 951(b) — U.S. shareholder defined
PILOT’s reasoning

A US person — Meridian — owns more than 50% (80%), so the foreign corporation is a CFC, and any US owner crossing 10% is a US Shareholder. Checked § 965 / PTEP history — no Category-1 temporality here.

Determines→Controlled Foreign Corporation
Fact sheet · Atlas Trading GmbH
  • 80% — Meridian Holdings LLC (US partnership)
  • 20% — German resident
  • Entity type — GmbH
  • Jurisdiction — Germany
  • No Form 8832 on file
  • Incorporated 2019
  • Mid-year capital contribution
  • Foreign accounts > $10,000
M5Filing Category Matching
builds on  CFC + US Shareholders
Authorities consulted
IRC §§ 6038 / 6046 — Form 5471IRC § 351 — §351 disclosure31 U.S.C. § 5314 — FBARIRC § 6038D — Form 8938
PILOT’s reasoning

Control of the CFC (80%) → Form 5471 Category 4, which subsumes the Category 5a US-shareholder requirement into one filing. The mid-year contribution of property for stock is itself a reportable stock acquisition → adds Category 3, and a § 351 disclosure. Foreign accounts over $10k → FBAR; specified foreign assets → Form 8938.

Determines→Form 5471 (Cat 3, 4, 5a) · §351 · FBAR · 8938
Fact sheet · Atlas Trading GmbH
  • 80% — Meridian Holdings LLC (US partnership)
  • 20% — German resident
  • Entity type — GmbH
  • Jurisdiction — Germany
  • No Form 8832 on file
  • Incorporated 2019
  • Mid-year capital contribution
  • Foreign accounts > $10,000
M6Report & Memo
builds on  Every determination
Authorities consulted
Pre-validated citation library (40+)
PILOT’s reasoning

Pulled validated citations for each determination (never paraphrased from memory). Composed the full memo — executive summary, facts, entity classifications, and the filing matrix — and generated the filing map. Every line traces to authority.

Determines→Citation-backed memo · filing map
21
IRS filings covered
6
module deterministic pipeline
100%
citation-backed memos
2018+
post-TCJA tax years

The real outputs

Explore an actual engagement.

These are the live components — drag the org chart, open a form on IRS.gov, flip through the actual memo. Exactly what your clients’ deliverables look like.

The part everyone dreads

“What did we file — how, and why?”

Big CPA firms and tax-law firms have the expertise and resources to do complex international analysis. Yet 9 times out of 10, two years later there’s no clean documentation of it to be found — right when someone needs the what, how, and why: a new partner on the account, a manager who just joined the firm, or a colleague picking up after a senior manager left.

Without PILOT

The reasoning is everywhere — and nowhere.

Buried in email threads
Lost in folders & share drives
A spreadsheet someone renamed
"In the manager's head" — who left
With PILOT

One retrievable record, with the “why” attached.

Every determination traced to its authority — in the memo, for good.
The org chart, maps, and per-entity analysis stored together in the Cabinet.
Roll forward next year — last year's reasoning carries with it.
Answer "why did we file that?" in one click, years later.

The math, conservatively

2 clients, 17 entities, professional analysis with memo-level documentation: 30+ hours / $10,000+ by hand.

With PILOT: minutes per entity, about $700 — finished with an audit-ready memo and visualizations.

Built for client data

Trust is the product.

Never used to train AI

Your client data is never used to train models.

Encrypted

Encrypted in transit and at rest.

Private to your firm

Isolated per firm — never shared or resold.

Audit-ready

Every determination traced to authority and retained.

FAQ

Questions, answered.

Is this just an AI black box?

No. PILOT's six-module pipeline is a deterministic rule chain: fact sheet in, structured JSON out. AI is used for extraction and narrative memo generation — but the filing determinations, entity classifications, ownership attributions, and form-category matches are all rule-driven, traceable to code, and testable. Every conclusion references a pre-validated statutory citation template — not a paraphrase.

How does PILOT prevent AI hallucination?

Four layers, all by design. (1) Filing determinations never run through an AI prompt — they are computed by deterministic rules over structured M1 fact-sheet data, the same way a CPA would work a checklist. The AI cannot 'decide' a Form 5471 category. (2) Every Anthropic Claude call uses structured-output tool-use with strict schemas (Zod-validated server-side) — the model returns shaped JSON, not free-form text, so a hallucinated key is caught at parse time and rejected. (3) Statutory citations come from a pre-validated 40+ template library, looked up by code; PILOT never asks AI to paraphrase a Code section or reg cite. (4) Ambiguous facts surface as Open Items — the engagement pauses for the Professional to resolve, instead of letting AI guess. The memo prose is the only place AI drafts narrative, and it drafts against the already-computed rule outputs (not against the raw facts) — so the prose can be inspected against the same rule outputs the CPA reviewed.

What's out of scope vs. in scope?

In scope: PILOT answers "what needs to be filed?" across 21 US outbound international filing artifacts — Form 5471, 8865, 8858, 8621, 926, 8938, FBAR, §351 disclosures, 3520/3520-A, 5472, 8854, 8833, §367(d) ongoing royalties, 1042/1042-S, 8804/8805, K-2/K-3, plus four computational triggers (8992, 8990, 8991, 8993) and a Foreign Tax Credit gate. Inbound filings (Form 1120-F, 1040-NR, and other categories) are on the PILOT roadmap — we expect to ship those capabilities before the end of 2026. Permanently out of scope for PILOT (by design): tax-liability computation, election modeling (§962, QEF, MTM, GILTI HTE), and actual return filing. Those belong to a separate Lodestar Tax Tech product — an automated workpaper workflow + form automation platform we are actively developing that picks up where PILOT leaves off. The two tools are designed to interoperate, but they will always be separate products with their own subscriptions. PILOT helps with the rote compliance triage so the Professional can focus on judgment work.

Can I cancel anytime?

Yes. Plans are month-to-month. Cancel before the next billing date and nothing further is charged. Engagement charges already incurred are not reversed. Founder Stage pricing locks your rate for as long as you maintain a continuous subscription — cancellation forfeits the lock.

Who's responsible if PILOT is wrong?

The Professional signing the return. PILOT is decision-support — a high-speed first-pass that a qualified US international tax Professional is expected to review before filing. Every engagement ships with a Scope Limitations section in the memo that documents the boundaries of PILOT's analysis. Errors should be reported to support@lodestartaxtech.com. If you need outsourced international tax expertise to sign off on the memo, reach out to the same address: Lodestar Tax Tech has internal Certified CPAs specialized in international tax available for additional fees. We are also expanding service lines to offer a white-label international tax director service — start-to-end consulting and compliance with sign-off authority on memos and forms — and will notify customers as soon as that service is in place.

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The first 8 entities are on us. No card to start. 30-day risk-free guarantee on everything after.

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PILOT by Lodestar — AI international tax filing analysis