The Countdown to the 2025 Tax Season Has Already Begun

Technical Wednesday. Hello, I’m CPA Maximiliano Mira Salas. In this new edition of our weekly newsletter, we address a key topic for companies, freelancers, and investors with U.S. structures: pre-season tax planning. Although the Tax Season hasn’t officially started, the coming months are crucial to organize accounting information, adjust records, and avoid last-minute filings. Early preparation not only reduces risks and penalties but also helps optimize deductions and tax credits, improving your structure’s net results. 📆 Why It Pays to Plan Ahead 📋 What You Can Do Now 📌 Legal and Accounting Disclaimer This communication is for informational purposes only and does not constitute legal, accounting, or tax advice. Each situation must be evaluated individually by a licensed professional, considering entity type, tax residency, and applicable international treaties. At FINANCERS, we assist companies, freelancers, and Latin American investors with U.S. structures before the start of Tax Season — ensuring technical and timely compliance with the IRS and state agencies, identifying required forms and reports, and optimizing deductions and tax positioning. Schedule your pre-season review today to avoid last-minute stress, penalties, and incomplete filings — plan ahead. CPA Maximiliano Mira SalasInternational Tax Advisor | FINANCERS 🇦🇷🇺🇸

International Taxes by Maximiliano Mira Salas

Hello and welcome to this Edition. I’m Maximiliano Mira Salas, and here I share topics on international taxation. Please tell your friends. Today I want to tell you about a consultation I received from Jorge B., a client who came to FINANCERS seeking tax advice for purchasing property in the U.S. His situation is one of many we see regularly, and you will probably identify if you are in a similar position. Summary Here is what happens. A nonresident signs a contract to purchase real estate in the U.S., which is considered a «U.S. real property interest.» The nonresident, Jorge, seeks tax advice regarding ownership structures. Instead of completing the purchase and taking title as an individual, Jorge creates a holding structure and assigns the rights under the purchase contract to that newly created structure, which then completes the purchase. That assignment of rights under the purchase contract is a «disposition» of a «U.S. real property interest» triggering two requirements: Both requirements are routinely ignored in practice. 🙂 But the technical requirements exist. «The basic rule for taxation of dispositions of real estate.» Section 897(a) contains the rule. Gain or loss is taxed when there is a «disposition» of a «U.S. real property interest» by a «nonresident alien or foreign corporation.» It is really more complicated than that. Section 897(a) says treat the gain or loss on that disposition «as if» it were income effectively connected with the conduct of a U.S. trade or business by that nonresident alien or foreign corporation transferor. More about that «as if» below. «U.S. real property interest» is more than just land and buildings A U.S. real property interest (abbreviated USRPI) includes more than just the land and buildings on it. A USRPI is: «Interest in real property» includes a purchase contract A nonresident visits the U.S. and falls under the spell of a real estate agent. Next thing you know, there is a contract to buy a beautiful house or condo, with the nonresident as the buyer. That purchase contract is an «interest in real property.» Treasury Regulation Section 1.897-1(d)(2)(ii)(B) states: «An option, contract, or right of first refusal to acquire any interest in real property (other than solely as a creditor) constitutes by itself an interest in real property other than solely as a creditor.» So if the nonresident buyer and the current owner (seller) have a signed contract enforceable in court by either party, the buyer is the owner of a real property interest. The real estate is in the U.S., so it is a USRPI. Oops, I want to use a holding structure In my world, people sign the contract to buy real estate in the U.S. and make an earnest money deposit. Then they come to me for advice on ownership structures. We talk about estate tax, then set up some sort of structure to protect the nonresident buyer from U.S. estate tax. Before closing, the individual (the named buyer) assigns their right to purchase the property (and the obligation to pay the purchase price) to the new holding structure. The seller consents. This is a «disposition» of a USRPI by a «nonresident alien.» Stop right there. We have a FIRPTA transaction defined by IRC Section 897(a), and a FIRPTA withholding requirement under IRC Section 1445(a). The right under the real estate purchase contract is an interest in real estate. It is a USRPI. You are a nonresident alien. You disposed of the USRPI when you assigned all your rights and obligations under the contract to your new holding structure. The assignment of the purchase contract fits perfectly within IRC Section 897(a)(1). Read the statute. You decide: «For purposes of this title, the gain or loss of a nonresident alien individual or foreign corporation from the disposition of a USRPI shall be taken into account: (A) in the case of a nonresident alien individual, under section 871(b)(1), or (B) in the case of a foreign corporation, under section 882(a)(1), as if the taxpayer were engaged in a trade or business within the United States during the taxable year and as if such gain or loss were effectively connected with such trade or business.» But there is no gain or loss Not exactly. Two issues arise: Tax return filing requirement Treasury Regulation Section 1.6012-1(b)(1)(i) states: «Except as provided in subparagraph (2) of this paragraph, every nonresident alien individual (not treated as a resident under section 6013(g) or (h)) who is engaged in a trade or business in the United States at any time during the taxable year or who has income subject to tax under Subtitle A of the Code shall file a return on Form 1040NR. For this purpose, it is irrelevant whether gross income for the taxable year is less than the amount specified in section 6012(a) for filing a return.» Do you understand? The mere fact of being engaged in a trade or business in the U.S. triggers a filing requirement for Form 1040NR for a nonresident alien. This is true even if there is no income. A small consolation: the last sentence of this Regulation makes preparing the return a bit easier. But the filing requirement remains. Does IRC Section 897(a)(1) make the taxpayer «engaged in trade or business»? Section 897(a)(1) uses the well-trodden «as if» language to define tax obligations. Usually, Congress uses «presumed,» but here it plainly states «as if.» Gain on disposition of a USRPI is treated «as if the taxpayer were engaged in a trade or business within the United States during the taxable year and as if such gain or loss were effectively connected with such trade or business.» If you are «engaged in trade or business,» you must file a tax return The mere fact of being engaged in a trade or business in the U.S. triggers a Form 1040NR filing obligation. Perhaps it is an abbreviated filing, but it exists. Treasury Regulation Section 1.6012-1(b)(1)(i) confirms it. And see the Form 1040NR Instructions.

U.S. Tax Season for Rental Income

Hello, I’m Cr. Maximiliano Mira Salas, and I want to tell you about the taxation of rental income in the U.S. for non-resident foreigners. When you own property in the U.S., you may face a 30% tax on gross rental income or, if you opt for “Effectively Connected Income” (ECI), you can be taxed on net income like a resident. This election allows you to deduct operating expenses and reduce your tax burden. Key Tax Obligations: Case Example: Form 5472 in ActionImagine Pedro, owner of an LLC in Miami for rental properties. If Pedro fails to file Form 5472 on time, his LLC may face fines up to $25,000. Also, without the W-8BEN, payments may be subject to a 30% withholding, impacting cash flow. Failure to timely file these forms can lead to penalties and operational difficulties in the U.S. FINANCERS makes your U.S. tax compliance easy so you can focus on your business. If this resonates with you, share it with your friends! Cr. Maximiliano Mira SalasInternational Tax Advisor | FINANCERS

Structure in BVI to Avoid Estate & Inheritance Tax in the USA

International Taxes. Hello, I’m Cr. Maximiliano Mira Salas, and I want to share with you a very important topic involving tax planning through the use of offshore structures—something many of our clients are considering to minimize state taxes in the United States. Cases Where State Tax Can Be Avoided: Cases Where State Tax Cannot Be Avoided: Conclusion.If you are considering a similar structure to minimize your state or estate taxes, remember that at FINANCERS we are here to help you navigate this process. With our expertise, you can achieve your tax goals without compromising your resources or peace of mind. Cr. Maximiliano Mira SalasInternational Tax Advisor | FINANCERS

General Guide on Taxation of Foreigners in the U.S. – Part Two

Technical Wednesday. Hello, I’m Cr. Maximiliano Mira Salas, and today I want to share the continuation of our exploration of IRS Publication 519, an essential guide to understanding how foreigners are taxed in the United States. If you’re a foreigner with income in the U.S., this topic is crucial for you. Residence Criteria and Tax Obligations To determine whether you must pay taxes as a resident or non-resident, the IRS uses tests such as the substantial presence test.• Residents: Report worldwide income.• Non-Residents: Only taxed on income generated within the U.S. Key Forms for Foreigners Complying with tax obligations requires identifying and filing the appropriate forms:• 1040NR: Tax return for non-resident aliens.• W-8BEN: Certifies non-resident status and reduces withholding taxes through international treaties.• 5472: Mandatory for single-member LLCs owned by foreigners.• 8854: Required for those ending their tax residency in the U.S. Rental Income: Tax Elections You Can Make If you own property in the U.S., you can choose: 👉 This election can significantly affect your tax burden but must be made correctly to avoid penalties. Key Dates for Tax Season Don’t let deadlines catch you off guard:• January 31: Contractor payment reports (1099-NEC).• March 15: Partnership and S Corporation returns (1065 and 1120S).• April 15: Individual and C Corporation returns (1040 and 1120). 💡 Remember: You can request an extension until October 15, but any balance due must be paid by April 15 to avoid penalties. Real Cases: How to Avoid Penalties • Form W-8BEN: If you export services to the U.S. and don’t file this form, 30% of your income may be withheld.• Form 5472: Failure to timely file for your LLC can result in a $25,000 penalty. 📌 Don’t worry, at FINANCERS we’re here to help!We handle your tax filings, optimize your tax burden, and help you comply with the IRS stress-free. 👉 If this applies to you or you know someone who needs it, share this with your friends!Contact us today and work peacefully

Payroll Management for Foreign Companies in the U.S.

Technical Wednesday. Hello, I’m Cr. Maximiliano Mira Salas, and today I want to share the key points for managing payroll in the U.S., which can be complex for foreign companies starting operations in this country. If you want to avoid common mistakes, ensure legal compliance, and optimize your accounting processes, this topic is essential for you! 💡 A common mistake: Many foreign companies assume that the regulations of their home countries also apply in the U.S., which is not the case. Adapting internal processes and having proper advisory is key to avoiding future problems. Proper payroll management not only guarantees legal compliance but also provides financial clarity and peace of mind to focus resources on business growth. As international accounting experts, at Financers we help many companies overcome these challenges. 👉🏼 If this resonates with you or you know someone who needs it, go tell your friends and work peacefully! Cr. Maximiliano Mira SalasInternational Tax Advisor | FINANCERS

How Do Non-Resident Aliens (NRAs) Pay Taxes in the United States?

Technical Wednesday. Hello, I’m Cr. Maximiliano Mira Salas, and today in our Technical Wednesday we will explore how Non-Resident Aliens (NRAs) pay taxes in the United States. This topic is essential for freelancers, entrepreneurs, and Latin American investors who work or invest in the U.S. market. If this applies to you, keep reading! What is an NRA? A Non-Resident Alien (NRA) is anyone who is neither a U.S. citizen nor a tax resident under U.S. government criteria. This means you are not subject to worldwide taxation like residents, but only on income that comes directly from activities or investments in the United States. For example, if you work from your country for a U.S. company or invest in a fund operating in the U.S., you will only pay taxes on those specific incomes according to applicable rules. LLCs: A Flexible Tool LLCs (Limited Liability Companies) are very popular legal structures among foreigners operating or investing in the U.S. As an NRA, the tax treatment of your LLC depends on the number of members: For example, if you operate an LLC to invest in real estate or financial funds in the U.S., the income derived from those activities will determine whether you must pay taxes or not. Types of Income: What is Taxed? The U.S. tax system distinguishes between two main types of income affecting NRAs: 1️⃣ Effectively Connected Income (ECI): Income directly related to a business or activity conducted in the U.S. For example, if you have a physical store or provide consulting directly in the country, this income is connected to economic activities there. 2️⃣ Fixed, Determinable, Annual, or Periodical Income (FDAP): This technical term includes passive income, such as interest, royalties, or dividends. For example, if you invest in a U.S. company that pays you dividends, this income is subject to specific rules, even if you have not performed any activity directly in the U.S. Practical Case: An LLC for Investing Imagine you decide to create an LLC in the U.S. to invest in stocks or funds. If that investment generates income, such as dividend payments, you will be subject to U.S. regulations, but in a much clearer and direct way than if you invested without a formal structure. Also, depending on how you configure the LLC and your activities, you could simplify your tax compliance. Why is it Important to Understand This? Understanding tax rules for NRAs is crucial to avoid problems and seize opportunities. A well-designed structure can help you optimize your operations and reduce risks. At FINANCERS, we handle these matters so you can focus on growing your business or investment. 👉 If you relate to this topic or know someone who might need this information, share this content and work peacefully! Cr. Maximiliano Mira SalasInternational Tax Advisor | FINANCERS

Prepare Your Tax Return with FINANCERS!

Technical Wednesday. Hello, did you know the tax return form for this year is already available? 📋If you work or invest in the United States, completing the form is the first step to fulfilling your tax obligations. Access the form here Frequently Asked Questions: 1️⃣ How do I download bank statements?• RelayFi: Go to the «Transactions» or «Statements» tab, select the date range, and download in PDF or CSV format.• Mercury: Go to «Banking,» select «Statements,» and download them in PDF.• Other banks: If you use other banks, make sure to download bank statements for all your accounts for the fiscal year in PDF format and attach them to the form. 2️⃣ What is a RA and where do I find it?It is your Registered Agent, who receives official documents on behalf of your company. Check your incorporation documents or the last state renewal. 3️⃣ What address do I declare for the partners?Declare the actual address: where they usually reside, receive services, or have official documentation. 4️⃣ What tax information do the partners need?• In the U.S.: ITIN or SSN.• In other countries: Tax identification number, such as CUIT in Argentina. 5️⃣ Why is information about travel, green cards, or citizen partners requested?This is key to determine your company’s tax status and comply with applicable rules. 🕒 Deadline: Complete the form before February 10 to avoid delays. 💬 Have questions? We’re here to help:• Email: admin@financers.com.ar / bookkeeping1@financers.com.ar• WhatsApp: Click here to write to us 📢 Share this information and help more people work peacefully 😊 Cr. Maximiliano Mira SalasInternational Tax Advisor | FINANCERS

Attention all LLC partners in the United States!

Technical Wednesday. If you have an LLC in the United States, it’s time to file your tax return. At FINANCERS, we are ready to support you throughout this process and ensure you meet your tax obligations efficiently, paying only what is fair. 💡 Access the form here ☑️ How to get started?Complete the form at the link provided and follow these steps:1️⃣ Enter your company’s basic information, such as name, phone, and contact email.2️⃣ Indicate if you have completed the form before:• Yes: We will work with the previous information to make the process easier.• No: We will request important data like your registered agent’s address and bank statements.3️⃣ The form will guide you step by step automatically. Just follow the instructions to complete it easily. 🗓️ Important deadlines:✅ March 15: For Multi-Member LLC (Form 1065).✅ April 15: For Single-Member LLC or Sole Proprietorship (Form 1040 with Schedule C). ❓ Frequently asked questions:💬 Are you a U.S. citizen? If you are Argentine, mark “No.” Only mark “Yes” if you have U.S. citizenship.💬 What if I don’t have an SSN or ITIN? Leave that field blank unless the form marks it as mandatory with an asterisk.💬 What should I put in the TAX ID? Enter your CUIT (Argentina). If they ask for EIN, provide the one assigned to your company.💬 Which bank statements should I upload? Include all your account statements from January through December 2024, either monthly or in an annual document.💬 Should I include savings or broker accounts? Yes, add statements from savings accounts and investments in platforms like Interactive Brokers, Schwab, or Ameritrade. 🚀 Don’t leave this to the last minute!Complete the form today and let’s work together so your tax return is a success. At FINANCERS, we make this process simple and effective.

Do you have an LLC? It’s time to file your Tax Return

If you work or invest in the United States, completing the form is the first step to complying with your tax obligations. Together with Las Contas, we explain the step-by-step process:Watch the video here At FINANCERS, we are ready to support you throughout this process and ensure it is simple and effective, paying only what’s fair. Complete the form today and let’s work together to make your tax return a success.Access the form here 🗓️ Important deadlines:✅ March 15: For Multi-Member LLC (Form 1065).✅ April 15: For Single-Member LLC or Sole Proprietorship (Form 1040 with Schedule C). 🚀 Don’t leave this to the last minute!If you need advice, at FINANCERS we are here to help you.