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FBAR

Foreign accounts >$10K

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FATCA

Form 8938 filing

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Form 5472

Foreign-owned LLCs

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BOI

Beneficial ownership

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Tax Treaties

Reduced withholding

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State Filings

Annual reports

Missing filings can result in penalties exceeding the value of underlying assets

Why Compliance Matters

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Foreign investors face multiple overlapping reporting requirements at federal and state levels.

Federal Requirements

  • FBAR for foreign accounts
  • FATCA Form 8938
  • Form 5472 for foreign LLCs
  • BOI beneficial ownership
  • Tax treaty forms (W-8BEN)

State Requirements

  • Annual reports
  • Franchise taxes
  • Foreign qualification
  • Registered agent
  • Business licenses

FBAR: Foreign Bank Account Reporting

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If you are a US person with foreign financial accounts exceeding $10,000 aggregate at any point during the year, you must file FinCEN Form 114.

Requirements

  • Threshold: $10,000 aggregate at any time
  • All foreign bank, securities accounts
  • Filed electronically via FinCEN BSA
  • Signature authority counts

Deadlines

  • April 15 initial deadline
  • Auto-extended to October 15
  • No extension request needed
  • Separate from tax return
Penalty: $10,000+ non-willful; $100,000+ or 50% of account for willful

FATCA: Foreign Account Tax Compliance

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US citizens and residents must report foreign financial assets on Form 8938 if they exceed threshold amounts. Separate from FBAR.

Requirements

  • Higher thresholds than FBAR ($50K+)
  • Attached to federal tax return
  • Bank accounts, securities, interests
  • Foreign institutions auto-report to IRS

Thresholds

  • US residents: $50K year-end, $75K any time
  • Foreign residents: $200K year-end
  • Married filing jointly: doubled
Deadline: With tax return (April 15 or extension)

Form 5472: Foreign-Owned LLC Reporting

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Every US LLC or corporation with 25%+ foreign ownership must file Form 5472 annually reporting transactions with foreign related parties.

Required For

  • Foreign-owned single-member LLCs
  • 25%+ foreign ownership
  • Disregarded entities for tax
  • Filed with pro-forma Form 1120

Reports

  • Capital contributions
  • Loans from/to foreign owner
  • Distributions
  • Related party transactions
Penalty: $25,000 per form per year + $25K per 30 days after IRS notice

Learn More: Form 5472 Complete Guide

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See our detailed Form 5472 guide for step-by-step filing instructions, examples, and common mistakes to avoid.

BOI: Beneficial Ownership Information

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The Corporate Transparency Act requires most US entities to report beneficial owners to FinCEN.

Report Includes

  • 25%+ owners or substantial control
  • Name, DOB, address
  • ID number and document image
  • Company applicant info

Deadlines

  • New entities: 90 days from formation
  • Existing entities: Check current rules
  • Updates: 30 days after changes
  • Corrections: 30 days after discovery
Penalty: $500/day civil; $10K fine + 2 years prison for willful

Learn More: FinCEN BOI Complete Guide

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See our detailed FinCEN BOI guide for filing instructions, exemptions, and deadline information.

Tax Treaty Benefits

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The US has tax treaties with many countries that can reduce withholding on dividends, interest, and royalties.

Forms Required

  • W-8BEN for individuals
  • W-8BEN-E for entities
  • Must be on file before payment
  • Valid for 3 years

Benefits

  • Dividends: 15% instead of 30%
  • Interest: Often 0%
  • Royalties: Reduced rates
  • Capital gains exemptions
Limitation on Benefits (LOB) provisions may apply

Delaware Requirements

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Annual Filings

  • Annual franchise tax (March 1)
  • Annual report
  • $200 late fee + 1.5%/month
  • Voided after 3 years non-payment

LLC Costs

  • $300 annual franchise tax
  • Registered agent required
  • No state income tax (no nexus)

Wyoming Requirements

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Annual Filings

  • Annual report ($60/year)
  • Anniversary month filing
  • No state income tax
  • Administrative dissolution risk

Benefits

  • Lower annual costs
  • Strong privacy laws
  • No franchise tax

California Requirements

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Annual Filings

  • $800 minimum franchise tax
  • Statement of Information
  • Required if doing business in CA
  • Foreign qualification needed

California Nexus

  • Physical presence triggers
  • Employees in CA
  • CA-source income
  • Significant CA sales

Annual Compliance Calendar

Jan 1

BOI Updates

Report ownership changes within 30 days

Mar 1

Delaware Franchise Tax

Annual report and franchise tax due

Mar 15

Corporate Returns

Form 1120 (C-corps), Form 1065 (partnerships)

Apr 15

FBAR, Form 5472, Individual Returns

Multiple deadlines converge

Jun 15

Non-Resident Returns

Auto 2-month extension for those abroad

Oct 15

Extended Deadlines

FBAR final; extended individual returns

Penalties for Non-Compliance

Filing Penalty
FBAR $10K+ non-willful; $100K+ or 50% willful
FATCA (8938) $10K + $10K/month after 90 days (max $50K)
Form 5472 $25,000 per form per year
BOI Report $500/day civil; $10K + 2 years criminal
State Reports $50-$500 late; administrative dissolution
Delaware Tax $200 late + 1.5%/month interest