International Taxation

Our home on Maui is a surprisingly cosmopolitan place.  We have foreign investors who purchase local businesses or real estate, foreign expatriates living in the United States, and U.S. citizens with foreign businesses and investments. 

Unfortunately, the United States has established extensive international reporting requirements, with substantial penalties for failure to stay in compliance.  For example, the failure to report a foreign bank account is a potential penalty of 50% of the highest value in that account for the year. 

In this environment, if you are a foreigner with investments in the U.S. or a resident with investments offshore, we can help you comply with these rules.

These include:

  • Form 114 - Report of Foreign Bank Accounts

  • Form 8938 - Statement of Specified Foreign Assets

  • Form 1040NR - Non-resident Individual Tax Return

  • Form 1120F - Foreign Corporation

  • Form 8865 - Return of U.S. Persons with Respect to Certain Foreign Partnerships

  • Form 5471 - Information Return of a Controlled Foreign Corporation

  • Form 5472 - Information Return of a 25% Foreign Owned Corporation

  • Form 8804 - Annual Return for Partnership Withholding Tax

Additionally, we have experience with beneficial treaty positions and foreign tax planning.

Please note this is not a comprehensive list of all U.S. International Tax Compliance services. U.S. tax treatment of foreign activities is a very broad practice area, and we do not have experience in all of them. We will not be appropriate for: Foreign Trusts, Personal Foreign Investment Companies (PFICs), Global International Low Taxed Income (GILTI), and many other international tax practice areas.