International Commerce Group Archives

Articles International Commerce Group International Tax Tax Law Resources

Form 5472: Partnership Attribution Rules

Foreign-owned U.S. companies and foreign corporations conducting a U.S. trade or business may have an unexpected Form 5472 filing obligation…

Deepika IyerNovember 3, 2026

Articles International Commerce Group International Tax

Form 8802: Plan Ahead for 2027 Tax Residency Certificates

TRC Reminder For 2027: A Practitioner's Guide to Timely Filing of U.S. Tax Residency Certificates For businesses and individuals with…

Osbert TokuOctober 6, 2026

Articles International Commerce Group International Tax Tax Law Legislation Tax Services

Foreign Tax Credits and the NIIT: Federal Circuit Rejects Treaty-Based Credit

On August 31, 2026, the U.S. Court of Appeals for the Federal Circuit ruled that the U.S.-Canada and U.S.-France income…

Ektaa ShahSeptember 8, 2026

Articles International Commerce Group International Tax

FBAR Deadline 2026: October 15 Filing Reminder

U.S. citizens and residents who held a financial interest in, or signature authority over, a foreign bank or financial account…

Deepika IyerSeptember 1, 2026

Articles International Commerce Group International Tax

U.S. Filing Requirements for a Foreign-Owned Single-Member LLC

For domestic U.S. tax purposes, a Limited Liability Company (LLC) with one owner is considered “disregarded” for U.S. federal income tax purposes,…

Robert EwanisAugust 18, 2026

Articles Individual Tax International Commerce Group International Tax Tax Services

Foreign Tax Credit Pitfalls for U.S. Citizen Children Abroad

As is the case with minor children living in the U.S., minor children living abroad may have U.S. tax filing…

Deepika IyerJuly 7, 2026

Articles International Commerce Group International Tax

US-India Tax Treaty: New IRS Ruling on Foreign Tax Credits

US tax residents who participate in the Indian equity market are often surprised to learn that gains from the sale…

Vinay NavaniJune 16, 2026

Articles International Commerce Group International Tax Tax Services

BEA Direct Investment Surveys: Filing Requirements Guide

Overview The U.S. Bureau of Economic Analysis (BEA) administers mandatory surveys of cross-border direct investment under the International Investment and…

Robert EwanisJune 9, 2026

Articles International Commerce Group International Tax

IRS Clarifies Form 5472 Penalty Relief

The IRS Office of Associate Chief Counsel (International) recently issued Chief Counsel Advice (CCA) 202617012 addressing when small foreign-owned corporations…

Franchelly Diaz ColonJune 2, 2026

Articles International Commerce Group Manufacturing, Distribution, & Logistics Tax Law Legislation

IEEPA Tariff Refunds: What Importers Need to Know

We are continuing to monitor developments related to IEEPA tariff refunds under the International Emergency Economic Powers Act, particularly in…

Bill McDevittApril 1, 2026