Insights

Notes from the practice

Short, statute-anchored writing for people whose money, company or life crosses the US border. No newsletters, no fluff.

Form 5471 (CFC & Foreign Corp Reporting)

Assuming dormant offshore entities do not require filing

Believing zero US income excuses filing for Delaware/Wyoming LLCs

Believing the $10,000 threshold applies per account rather than aggregated across all accounts

Confusing Form 8938 with FBAR — both are often required simultaneously with different asset scopes

Counting days in international waters or transit towards the 330-day requirement

Failing to elect Section 962 for individual shareholders, leading to up to 37% tax without FTCs

Buying European UCITS ETFs or local mutual funds unaware they are classified as PFICs

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