International Tax

GILTI and Subpart F

GILTI and Subpart F review requires coordinated ownership data, foreign corporation financials, E&P, PTEP, foreign taxes, income categories, and U.S. owner return positions. MMVFO helps organize the fact pattern and specialist calculations so inclusion issues are not discovered after filing.

International reporting map connecting FBAR, Form 8938, foreign entities, PFICs, trusts, and U.S. reporting

International Tax

International reporting map

Cross-border work is mapped by accounts, assets, entities, trusts, investments, filing history, and penalty-sensitive facts.

CFC ownership map

Confirm U.S. shareholder status, control, attribution, ownership changes, and Form 5471 filing category signals.

Income category review

Separate tested income, tested loss, Subpart F income, passive income, related-party income, and local-country financial statement data.

Tax attributes and credits

Coordinate E&P, PTEP, foreign taxes, foreign tax credit limitations, Section 962 questions, and owner-level return effects.

Data and calculation workflow

Identify the foreign books, trial balances, tax returns, entity records, and specialist inputs needed for calculations.

Planning and remediation boundaries

Prospective structuring, elections, legal opinions, and penalty remediation should be handled with qualified tax specialists and counsel where needed.

FAQs

No. They are separate regimes with different mechanics and require specialist review.
Yes. Foreign taxes, credit limitations, and owner-level facts can be central.
No. CFC status, income, ownership, and other facts must be reviewed.
It is much harder. Foreign entity data should be gathered early because calculations can affect the full return.

Request a Private Tax Strategy Diagnostic

If your tax, entity, investment, estate, insurance, or reporting picture has become too complex for one advisor to see clearly, MMVFO can help map the moving parts.

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Reviewed by Joshua V. Azran, CPA/ABV/CFF, CMA, CGMA, CFE and Lorenzo Abbatiello, CPA | Last updated