Resources

US international filing guidance and information CPAs and tax attorneys can utilize — with the authority behind it.

• Form 5471OBBBA Changes UpdatedWho must file Form 5471, and what category applies? (Updated for OBBBA)A determination framework for US persons with an interest in a foreign corporation — the ownership tests, the §958 attribution that drives them, and how to land on the right filer category.Revised June 2026
• Form 8621OBBBA Changes UpdatedWho must file Form 8621, and is the foreign company a PFIC? (Updated for OBBBA)A determination framework for US persons who own a foreign corporation that may be a passive foreign investment company — the two §1297 tests, the CFC overlap, and who carries the §1298(f) filing obligation.Revised June 2026
• Form 8938 / FBARNo OBBBA ChangeFBAR vs Form 8938: who files which, and how do they differ?A side-by-side of the two foreign-asset disclosures — different agencies, different thresholds, and a different reach (financial accounts versus a broader set of assets) — covering who files which, why signature authority and entity interests split them, and why many people file both.Revised June 2026
• Form 8865No OBBBA ChangeWho must file Form 8865, and which category applies?A determination framework for US persons with an interest in a foreign partnership — the control and 10%-interest tests, the §267(c) attribution that drives them, and how to land on the right one of the four filer categories.Revised June 2026
• Form 8858No OBBBA ChangeWho must file Form 8858, and which category applies?A determination framework for US persons who own a foreign disregarded entity or operate a foreign branch — the classification gate that sets Form 8858 apart from Form 5471 and Form 8865, the "tax owner" test that decides who files, and how to land on the right one of the six filer categories.Revised June 2026
• Form 5472No OBBBA ChangeWho must file Form 5472, and what triggers it?A determination framework for the inbound side of the international forms — the three kinds of reporting corporation (a 25%-foreign-owned US corporation, a foreign corporation engaged in a US trade or business, and a foreign-owned US disregarded entity), the reportable-transaction gate that actually triggers the form, and the exceptions that switch it off.Revised June 2026
• Form 926No OBBBA ChangeWho must file Form 926, and what transfers trigger it?A determination framework for US persons who transfer property — cash, stock, intangibles, or a whole business — to a foreign corporation: who is the transferor, the tax-free exchanges that put the transfer on the form, the cash carve-out, the §367 tax that rides on top, and the exceptions that switch the filing off.Revised June 2026
• Form 3520 / 3520-ANo OBBBA ChangeWho must file Form 3520 or 3520-A, and what triggers each?A determination framework for US persons who deal with a foreign trust — transferring to one, being treated as its owner, or taking a distribution — and for US recipients of large foreign gifts: the two forms, the four reporting triggers, the US-versus-foreign-trust gate, and the unusually steep penalties.Revised June 2026
• Form 1042 / 1042-SNo OBBBA ChangeWho must file Form 1042 or 1042-S, and what triggers withholding?A determination framework for withholding agents that pay US-source income to foreign persons — what makes someone a withholding agent, the FDAP income subject to 30% withholding, the effectively-connected income that is not, the Chapter 4 (FATCA) overlay, and the personal liability that rides on the two forms.Revised June 2026
• Form 8804 / 8805No OBBBA ChangeWho must file Form 8804 or 8805, and what triggers partnership withholding?A determination framework for partnerships with foreign partners — the three-part trigger (a partnership, income effectively connected with a US business, and a foreign partner who shares in it), why the return is due even when no tax is owed, the rates and the partnership’s own liability, and the transfer-of-interest withholding that belongs on a different form.Revised June 2026
• Form 8992OBBBA Changes UpdatedWho must file Form 8992 (GILTI), and what changed under OBBBA?A determination framework for US shareholders of a controlled foreign corporation — the 10% US-shareholder and CFC tests that put a GILTI inclusion on the table, the partnership pass-through that decides who actually files, and the line between flagging the form and computing the inclusion.Revised June 2026
• Form 8990OBBBA Changes UpdatedWho must file Form 8990 (the §163(j) interest limitation), and how does it reach foreign structures? (Updated for OBBBA)A determination framework for the §163(j) business-interest limitation — brief on the general 30%-of-income mechanics, and focused on the international side: how the limit applies inside a controlled foreign corporation, attaches to Form 5471, and how OBBBA reshaped the income base it is measured against.Revised June 2026
• Form 8993OBBBA Changes UpdatedWho must file Form 8993 (the §250 FDII and GILTI deduction), and what changed under OBBBA?A determination framework for the §250 deduction a C corporation claims on Form 8993 — the deduction against its GILTI inclusion and the deduction for its foreign-derived income, why it is a benefit with no filing penalty, and the line between flagging that it is potentially available and computing it.Revised June 2026