Features

How PILOT works, and what it covers.

A look inside the six-module pipeline, the filing forms PILOT determines, and the work product you hand off.

The six-module pipeline

Each module reads, reasons against the Code, and passes its determination to the next.

21 filing forms, by tier

PILOT’s scope is US outbound international filing obligations — 21 forms, organized the way an engagement classifies them.

Required

16 forms, determined from the fact sheet
Form 5471 ↗

Controlled foreign corporation reporting

IRC §§ 6038, 6046
Form 8858 ↗

Foreign disregarded entity

IRC §§ 6011, 6038
Form 8865 ↗

Foreign partnership

IRC §§ 6038, 6038B, 6046A
Form 8621 ↗

PFIC reporting

IRC § 1298(f)
Form 926 ↗

Outbound asset transfers

IRC § 6038B
Form 8938 ↗

Specified foreign financial assets

IRC § 6038D
FBAR (FinCEN 114) ↗

Foreign bank & financial accounts

31 U.S.C. § 5314
§351 Disclosure

Transfer to a controlled corporation

IRC § 351 · Reg § 1.351-3
Form 3520 / 3520-A ↗

Foreign trust & large foreign gift

IRC §§ 6048, 6039F
Form 5472 ↗

25%+ foreign-owned US corporation

IRC § 6038A
Form 8854 ↗

Expatriation statement

IRC § 877A
Form 8833 ↗

Treaty-based return position

IRC § 6114
§367(d) royalty

Ongoing annual royalty on outbound IP

IRC § 367(d)
Form 1042 / 1042-S ↗

NRA payee withholding

IRC §§ 1441, 1442
Form 8804 / 8805 ↗

Foreign-partner ECI withholding

IRC § 1446
Schedules K-2 / K-3 ↗

Partnership / S-corp international schedules

Conditional

1 form, gated on a single fact
Form 1116 / 1118 ↗

Foreign tax credit — when the return claims it

IRC §§ 901–904

Potential

4 computational triggers
Form 8992 ↗

GILTI calculation

IRC § 951A
Form 8990 ↗

Business interest expense limitation

IRC § 163(j)
IRC § 59A
Form 8993 ↗

FDII / §250 deduction

IRC § 250

Technical Depth

Wonder if PILOT can get this right?

The rules where the detail gets lost.

A handful of international-tax rules are where engagements quietly go wrong — experts disagree, seasoned practitioners slip, and general-purpose AI answers them confidently wrong.

Here are nine. For each: the trap, the rule, and the exact authority PILOT pins it to — we leave hallucination no room to breathe.

Every quotation & citation below is drawn from PILOT’s own knowledge base — §958(a)/(b), Form 8621, §6038/§6038A. Nothing here is generated from a general-purpose LLM’s memory.

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.

Why PILOT

What makes the output something you can hand a partner — or an examiner — two years later.

Deterministic, not a black box

Filing determinations are computed by rules over your fact sheet — the AI never decides a form. Traceable to code, and testable.

Citation-backed

Each conclusion references a pre-validated statutory citation template — looked up, never paraphrased from memory.

Audit-defensible, years later

The what, how, and why live in one retrievable record — ready when a new partner or an examiner asks.

It pauses instead of guessing

Anything ambiguous or value-dependent surfaces as an open item for you to resolve — no silent assumptions.

Private to your firm

Your client data is never used to train models, and stays isolated to your firm.

Specialist-grade, in plain English

Specialist-level international analysis, written so any CPA or attorney — and the client — can read it and act. No international-tax expert needed on staff.

Run your first engagement free.

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

Features · PILOT by Lodestar