Key Takeaways Form 8858 Penalty Structure: Initial penalty: $10,000 per form, per year Continuation penalty: $10,000 per 30-day period after IRS notice Maximum penalty: $50,000 per form, per
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Form 8858 vs Form 5471: Key Differences Explained
Key Takeaways Form 8858 vs Form 5471: What You Need to Know Form 8858 reports foreign disregarded entities (FDEs) and foreign branches Form 5471 reports controlled foreign corporations
FBAR vs Form 8938: Key Differences Explained
Both FBAR and Form 8938 require reporting foreign financial accounts. But they go to different agencies, have different thresholds, and cover different assets. Many taxpayers need to file
FBAR Deadline 2026: Filing Dates & Automatic Extension
If you have foreign financial accounts, the FBAR deadline is one date you can’t afford to miss. The good news: there’s an automatic extension that gives you extra
Section 179 Deduction Guide 2025: $2.5 Million Limit Under New Tax Law
TL;DR: The One Big Beautiful Bill Act (signed July 4, 2025) doubled Section 179 limits. You can now expense up to $2.5 million in qualifying equipment and property
Form 8865 Constructive Ownership Rules: Section 267(c) Attribution Explained
Last Updated: January 18, 2026 | International tax CPA firm with Big Four experience Key Takeaways Constructive ownership determines if you meet 10% or 50% Form 8865 thresholds Uses Section 267(c)
Section 721(c) Partnerships: Form 8865 Schedule G and H Requirements
Last Updated: January 18, 2026 | International tax CPA firm with Big Four experience Key Takeaways Section 721(c) applies to partnerships formed on or after January 18, 2017 Triggered when a
Form 8865 Schedule K-2 and K-3: International Tax Reporting Requirements
Last Updated: January 18, 2026 | International tax CPA firm with Big Four experience Key Takeaways Schedule K-2 reports partnership-level international tax items Schedule K-3 reports each partner’s share of K-2
Form 8865 vs Form 1065: Key Differences Explained
Last Updated: January 18, 2026 | International tax CPA firm with Big Four experience Key Takeaways Form 1065: Filed by partnership entities (domestic partnerships) Form 8865: Filed by U.S. persons with
Form 8865 Schedule O: Property Transfer Reporting Requirements
Last Updated: January 18, 2026 | International tax CPA firm with Big Four experience Key Takeaways Schedule O reports property contributions to foreign partnerships under Section 6038B Required for Category