🌐 CROSS-BORDER TAX ADVISORY

International Tax & Cross-Border Compliance in Miami

Navigating U.S. Tax Obligations, Withholding Rules, and Cross-Border Reporting for Global Investors and Businesses.

Global Investors & U.S. Compliance

Protecting cross-border wealth and preventing IRS foreign penalties

CROSS-BORDER SPECIALISTS

Your Bridge Between Global Assets and the U.S. Tax System

Miami is the commercial gateway connecting international capital and foreign entrepreneurs to the United States. However, the U.S. Internal Revenue Code enforces some of the world’s strictest cross-border tax rules.

At ACP Tax Advisory, we protect foreign investors, non-resident property owners, and international families from strategic IRS penalties while structuring their operations for maximum tax efficiency.

Core International Tax Solutions

Specialized cross-border compliance where mistakes are costly and strategic precision is vital.

Foreign-Owned Entities (Form 5472)

Informational reporting for 25%+ foreign-owned U.S. corporations and foreign-owned single-member LLCs (disregarded entities) engaged in reportable transactions under IRC Section 6038A/6038C.

Non-Resident Returns (Form 1040-NR)

Accurate filings for foreign individuals earning U.S. rental income, dividends, or capital gains, optimizing treaty provisions.

FIRPTA Withholding Support

Tax compliance under FIRPTA for foreign sellers of U.S. real property interests. We calculate anticipated tax liabilities and prepare Form 8288-B withholding certificates to seek reduced withholding prior to closing.

FBAR (FinCEN 114) & FATCA (8938)

Annual reporting of foreign financial accounts and offshore assets for U.S. tax residents to ensure complete regulatory compliance.

International Tax Frequently Asked Questions

Form 5472 is an annual IRS informational report required when a 25% or greater foreign-owned U.S. corporation or a foreign-owned single-member LLC (treated as a disregarded entity for U.S. tax purposes) engages in reportable transactions with related parties. Because failure to file or filing incomplete forms triggers severe statutory penalties ($25,000 per applicable form under IRC Section 6038A), proper technical analysis of entity tax classification and reportable transaction flows is essential.
Under FIRPTA, the buyer or closing agent must generally withhold up to 15% of the gross sales price when acquiring a U.S. real property interest from a foreign person, unless specific statutory exemptions apply. ACP Tax Advisory assists foreign sellers with preparing IRS Form 8288-B (Application for Withholding Certificate) prior to closing to seek reduced withholding based on the actual maximum tax liability, or preparing post-closing Form 1040-NR returns to claim eligible refund balances.
A foreign-owned single-member LLC treated as a disregarded entity must file Form 5472 along with a pro forma Form 1120 if any reportable transactions occurred during the tax year (such as initial capital contributions, payment of formation costs, owner loans, or routine business expenditures), even if the company earned zero commercial revenue.
Absolutely. We frequently collaborate with accountants and legal counsel in Brazil, Latin America, and Europe to harmonize cross-border tax treatment and avoid double taxation.

Build Your Cross-Border Tax Strategy in Miami

Protect your foreign investments and ensure flawless IRS compliance with ACP Tax Advisory.