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You are here: Home / Monographs / Preparing U.S. Tax Returns for International Taxpayers

Preparing U.S. Tax Returns for International Taxpayers

cover of 951A GILTI monographNeed to learn how to prepare U.S. tax returns for international taxpayers? For example, do you need to report the Section 965 transition tax? Or the new Section 951A GILTI tax? Do you need to file 5471 returns?

You may want to purchase, download and read Preparing U.S. Tax Returns for International Taxpayers (price $150).

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Updated for regulatory guidance provided through November 23, 2018, this roughly 180-page monograph provides actionable information, downloadable worksheets, and practical client organizers you can use to help clients comply with the new international disclosure requirements as well as the complex new international taxes.

Note: The actual downloadable file is a zip file which holds both a pdf document and an Excel workbook.

Money Back Guarantee

We’re of course providing a money-back guarantee… If you don’t find our monograph saves you days of time and lets you more quickly help clients comply with the new complicated international taxpayer taxes, just email us and ask for a refund.

What’s in the Monograph

The monograph breaks down the complex subject of outgoing international taxation into 15 easy-to-digest chapters and 3 useful appendices:

Chapter 1 – Introduction sets the stage for the rest of the monograph by talking about how the monograph organizes its information and approaches the subject matter.

Chapter 2 – The Infamous Worldwide Income Tax explains and discusses the U.S.’s unique conceptual approach to international taxation, which is to tax the worldwide income of its citizens and businesses.

Chapter 3 – Foreign Tax Credit describes how the foreign tax credit works, how it partially eliminates U.S. taxpayers from paying income taxes twice on the same income, and how the key loophole-closing provisions of the foreign tax credit work.

Chapter 4 – Special Rules for Foreign Earned Income reviews how the foreign earned income exclusion works and explains in detail when the foreign earned income exclusion and the related housing exclusion saves U.S. taxpayers from paying U.S. income taxes. A caution? Careless taxpayers regularly use these exclusions when they actually shouldn’t. (Often because they don’t understand the “tax home” concept.)

Chapter 5 – Tax Treaties introduces how tax treaties fit into the U.S. international taxation regime. Tax treaties often have a significant impact on U.S. taxation related to international investments. (Thankfully, however, these treaties often tend to be pretty cookie-cutter.)

Chapter 6 – Currency Conversions provides a quick overview of how to convert foreign currency amounts into U.S. dollar amounts for U.S. tax returns.

Chapter 7 – Understanding Subpart F explains why, when and how some foreign corporation income gets passed through and taxed on a U.S. taxpayers’ U.S. tax return. Practitioners and taxpayers need at least a basic understanding of Subpart F to deal with the new taxes many international U.S. taxpayers now face.

Chapter 8 – Calculating the Section 965 Transition Tax describes the one-time Section 965 transaction tax that blindsided many small businesses in 2017 and 2018. The chapter also explains how practitioners calculate and report this absurdly complicated new tax… or how they amended a tax return and belatedly report the tax.

Note: The Preparing U.S. Tax Returns of International Taxpayers  monograph comes with an Excel workbook that supplies the Section 965 worksheets described in and required by IRS Publication 5292.

Chapter 9 – Global Intangible Low-Tax Income (GILTI) discusses and explains the new Section 951A GILTI tax which U.S. taxpayers owning more than 10% of a controlled foreign corporation will now need to pay on their pro rata share of foreign corporation earnings, as well as the new Section 250 Foreign-derived intangible income deduction.

Chapter 10 – Section 962 Elections describes the Section 962 election, how it potentially reduces both the Section 965 transition tax and the Section 951A GILTI tax, and then walks readers through the steps for making the election.

Chapter 11 – Tricky Transactions Using Foreign Entities explains and dissects a number of techniques and tactics that international taxpayers have in the past used to dial down their U.S. tax burden: transfer pricing, covered asset acquisitions, and reportable transactions.

Chapter 12 – Attempts at Propping Up U.S. Exporters briefly discusses most of the important historical gambits that U.S. lawmakers have orchestrated to help multinational businesses—and their current-day legacy and impact. This information can provide useful context for understanding the U.S.’s current approach to international taxpayers.

Chapter 13 – Miscellaneous Issues Related to International Business briefly explains a handful of related important compliance issues, including boycott reporting, customs duties and sanctions. Practitioners with international footprint clients will need to possess a working knowledge of these topics.

Chapter 14 – The Long Saga of U.S. Attempts at Catching Offshore Tax Evasion recounts how the U.S. has historically approached offshore tax evasion and then discusses the current, very effective system the U.S. employs to identify and punish taxpayers who fail to follow the law.

Chapter 15 – Preparing the FinCEN 114 Form and the 8938 Form steps you through the process for preparing the two most common disclosure forms for international taxpayers. (This chapter and the next one should be viewed as supplements to and not replacements for the form instructions.)

Chapter 16 – Preparing the 5471 Forms explains how the 5471 forms work to disclose and document the ownership interests of U.S. taxpayers who own shares in controlled foreign corporations. This complicated set of forms provide the foundation for calculating and reporting the Section 965 transition tax and the Section 951A GILTI tax.

Chapter 17 – A Brief Overview of the Current Reporting Rules quickly wraps up the monograph’s discussion by identifying the different forms used for reporting international tax information and then it also discusses the steps taxpayers and their tax advisers want to take if they’ve goofed up their international tax accounting in the past.

Appendix A – Example 5471 Forms provides a simple example of a set of 5471 forms for a controlled foreign corporation. The example includes the Section 965 transition tax.

Appendix B – Sample International Taxpayer Organizer supplies a recyclable tax organizer that practitioners can use to collect the needed information from their international footprint clients.

Appendix C – Example 5471 Organizer supplies a recyclable tax organizer that practitioners preparing 5471 forms can use to collect needed information for controlled foreign corporations.

About the Author

CPA Elizabeth C. Nelson is tax manager of a Seattle-area public accounting firm that provides tax accounting services to numerous entrepreneurs and investors with an international footprint. Nelson holds a BS in accounting Western Governors University.

She is the co-author of two other tax monographs: Preparing Form 3115 for the Tangential Property Regulations and Small Businesses and the Affordable Care Act, which thousands of CPAs have purchased and read to quickly learn complex new tax statutes and regulations.

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