Whether principals live abroad or hold foreign entities, you need a US-side CPA partner coordinating CFC reporting, FIRPTA withholding, treaty elections, and FBAR compliance. Max Panchuk holds three passports. That background is supporting credibility, not the headline.
Cross-border owners often look profitable on paper while cash is trapped in withholding, trapped foreign accounts, or lifestyle bleed across currencies. We act as year-round CPA advisors, protecting structure, cash flow, and compliance together, not filing returns in isolation.
The structural moves that compound on a 5-10 year grow-then-exit horizon, engineered, documented, and stress-tested years before a transaction is on the table.
Non-residents selling US property face 15% federal + state withholding at close. We've reduced federal to under 3% and state by 80%, recovering $20K to $500K in closing liquidity per transaction via 8288-B applications.
Foreign account reporting penalties can dwarf the accounts themselves. We've eliminated $700K+ in FBAR penalties through streamlined filing programs and structured voluntary disclosure, when the facts and the applicable program support reduced penalty exposure.
Controlled foreign corporation (CFC) reporting, Form 5471 compliance, and Subpart F / GILTI modeling for US owners of foreign entities. We coordinate treaty elections, foreign tax credits, and dual-status returns across Canada, UK, Germany, Australia, and 14+ treaty partners, with a US-side team that stays in the file year-round.
Renouncing citizenship triggers an exit tax on unrealized gains. We model the tax cost, time the renunciation against asset positioning, and coordinate the dual-year filing, before the IRS sees the deemed disposition.
Canadian seller of US real estate faced standard 15% FIRPTA withholding plus state. Through 8288-B application, treaty election, and timely filing, we reduced federal withholding to under 4% and structured the gain through treaty provisions, saving $890K and eliminating three quarters of dual-country complexity. “They handled three countries of tax obligations in a single engagement.”. Canadian Seller, Vancouver
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Standard FIRPTA withholding is 15% of the gross sale price, plus applicable state withholding. California Form 593 withholding depends on the facts. Exemptions and alternative gain-based computations can apply. It is not a universal 3.33 percent of sale price. For many sellers, default withholding exceeds the actual tax owed. An 8288-B withholding certificate filed before close can reduce federal withholding toward expected tax.
California Form 593 can apply on sales of California real property by nonresidents. The amount is not a universal 3.33 percent of sale price. Exemptions and alternative gain-based computations exist. We model federal FIRPTA and California Form 593 together before close.
We are licensed CPAs acting as year-round advisors, not product salespeople. Structure, cash, and filings stay in one file. Exit-tax modeling for expatriation is planning before anyone files Form 8854, not a product pitch.
Streamlined filing is generally for non-willful failures. Voluntary disclosure is a different path, often used when willfulness is a concern. Penalty results and any criminal-referral risk depend on the facts, the program, and IRS discretion. We do not recommend a path without a full conduct review, and we do not describe either program as categorical criminal-referral protection.
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