#international-tax
Cross-border tax compliance, foreign income reporting, and US international tax obligations for individuals and corporations
Form 8865 makes U.S. persons report controlled foreign partnerships, property contributions, and 10-percentage-point interest changes. Missing it triggers $10,000 per partnership per year, plus a 10% foreign tax credit haircut and stacking 30-day penalties up to $50,000.
U.S. multinational groups with $850 million or more in consolidated revenue must file Form 8975 with one Schedule A per tax jurisdiction. This guide walks through the four-part threshold test, the Schedule A line items, the Pillar Two transitional safe harbor that now relies on CbCR data, and the five filing mistakes that most often trigger audits in the 2026 cycle.
U.S. multinationals with $850M+ in consolidated revenue file Form 8975 with Schedule A per jurisdiction. In 2026 the report also gates the OECD Pillar Two transitional safe harbor at a 17% simplified ETR — making CbC data accuracy a strategic, not clerical, priority.
Schedules K-2 and K-3 pulled even purely domestic partnerships and S-corps into international tax reporting starting in 2021. This guide explains the 2026 filing rules, the four-condition domestic filing exception, the January 15 partner notification and February 15 1-month K-3 request deadlines for calendar-year filers, the $250,000 small entity carve-out added in 2024, and the per-partner, per-month penalty math for non-compliance.
The Corporate Alternative Minimum Tax imposes a 15% levy on Adjusted Financial Statement Income for corporations averaging over $1 billion in AFSI. A practical guide to who qualifies, how AFSI is computed under section 56A, the FPMG $100M U.S. test, Form 4626 mechanics, and the interim simplified safe harbor.
Under OBBBA, Section 250 renames FDII to FDDEI, sets the deduction at 33.34%, eliminates the QBAI offset, and removes interest and R&E allocation — producing an effective 14% federal rate on qualifying foreign-derived income for U.S. C corporations filing Form 8993 in 2026.
A working guide to the FDII (now FDDEI) deduction on Form 8993 — which U.S. C corporations qualify, how the Section 250 math drops the effective federal rate to 13.125% on foreign-derived income, the taxable income limitation, documentation the IRS expects, and how OBBBA simplifies the calculation starting in 2026 by removing the QBAI step and expense allocations.
The IC-DISC is the only permanent federal tax incentive dedicated to U.S. exporters that is available to pass-through entities. It routes export commissions through a tax-exempt paper corporation and back out as qualified dividends, cutting the effective federal rate on export profits from roughly 40% to 23.8% for closely held manufacturers, distributors, software vendors, and engineering firms.
An IC-DISC is a paper-only U.S. C corporation authorized by IRC Sections 991–997 that lets closely-held manufacturers, distributors, and growers convert qualifying export profit from ordinary income rates (up to 37%) into qualified dividend rates (20–23.8%), with typical setups producing $50,000+ in annual federal tax savings on $5M of qualifying export sales after Section 199A's 2026 sunset widened the rate spread.
How U.S. partnerships and S corporations qualify for the Schedule K-2/K-3 domestic filing exception, manage the 1-month-date partner request rule, and use the new small-entity exception for entities with under $250,000 in total receipts.
Subpart F forces U.S. shareholders of a controlled foreign corporation to recognize foreign profits as current-year income, even when no cash is distributed. This guide covers the 10 percent threshold, the four triggering income categories, Section 958 constructive ownership traps, Form 5471 penalties, and how the 2026 OBBBA rewrite (NCTI, restored 958(b)(4), 40 percent Section 250 deduction) reshapes the rules.
How U.S. shareholders of foreign corporations are taxed on undistributed profits in 2026: the 10 percent threshold, Section 958 constructive ownership, Form 5471 filing duties, and the OBBBA rewrite that replaced GILTI with Net CFC Tested Income (NCTI).
