Do’s and Don’ts of Offshore Compliance

You don’t need to hide money to get tripped up by offshore rules. Most noncompliance I see comes from simple oversights—opening a foreign bank account for a child at university, investing in a foreign mutual fund, setting up a holding company for an overseas hire, or receiving a gift from abroad—and then missing the follow-on filings. The good news: offshore compliance is manageable when you treat it like a process, not a scramble. This guide distills what works in practice, where people go wrong, and a step-by-step path to getting and staying compliant.

Why offshore compliance is different now

Automatic information exchange transformed the landscape. Banks and governments swap account data routinely, and the data quality keeps improving.

The OECD’s Common Reporting Standard (CRS) now connects over 120 jurisdictions. The OECD reported that recent exchanges covered more than 120 million financial accounts holding roughly €12 trillion in assets. That’s a lot of matching against tax returns.

The U.S. requires foreign financial institutions to identify U.S. clients under FATCA. More than 100 jurisdictions have signed intergovernmental agreements to implement it.

Audits are becoming more data-driven. The IRS, backed by fresh funding, has signaled a focus on high-wealth individuals, pass-through entities, and cross-border enforcement.

Financial institutions have tightened KYC/AML and substance requirements. If your entity structure lacks business purpose or real activity, expect bank friction and potential account closures.

The net effect: secrecy is out; transparency is the baseline. Compliance is less about “avoiding detection” and more about aligning reporting across multiple systems that now talk to each other.

Who needs to care

You’re in the offshore compliance orbit if any of these are true:

You’re a U.S. citizen or resident with foreign bank or investment accounts, foreign business interests, or foreign trusts.

You live abroad (expat) but keep U.S. filing obligations, or you’re a non-U.S. person with U.S. investments or operations.

You own or manage entities that pay or receive cross-border interest, dividends, royalties, or services, or that hold non-U.S. assets.

You use foreign companies for hiring or contracting, run a marketplace business, invest through offshore funds, or operate in multiple jurisdictions.

I also see a growing group of “accidental” filers—digital nomads, remote-first founders, and families with cross-border estates—who never intended to be complex but ended up there after a few life choices.

The big picture: how information flows

Here’s how governments and banks triangulate:

Banks onboard you with self-certifications (FATCA/CRS). If your self-cert contradicts other data (passport, tax residency, mailing address), flags go up.

Banks report your accounts to tax authorities. Under FATCA, data on U.S. persons is sent to the IRS (typically via the local authority). Under CRS, jurisdictions exchange among themselves.

Governments match the data to your returns. Missing or inconsistent forms—like FBAR, Form 8938, 5471, 3520—trigger notices or audits.

Withholding agents collect tax at source. If you’re a non-U.S. person earning U.S. income, failure to provide a valid W-8 generally means 30% withholding. Misfilled forms cause over/under-withholding and potential penalties for the payer.

Understanding that information flows regardless of your intention helps you design filings that align with what’s reported about you.

The do’s

Do map your cross-border footprint

Create a single-page diagram of your personal and business situation:

Tax residencies (past 3–5 years), citizenships, visas, and physical presence days.

Entities (companies, partnerships, trusts, foundations), with ownership percentages and roles (director, trustee, protector).

Financial accounts and investments by jurisdiction.

Income streams (employment, dividends, interest, royalties, crypto, real estate).

Advisors and banks involved.

This map prevents the number-one mistake: forgetting a piece of the puzzle and discovering it after a notice arrives.

Do keep clean records from day one

Keep opening statements for every account, and annual year-end statements.

Maintain basis and lot-level details for investments—especially foreign funds.

Archive organizational documents for every entity: certificates, articles, minutes, resolutions, share registers, trust deeds, letters of wishes.

Track foreign tax paid by category and country. It drives your foreign tax credit calculations.

Save currency conversion evidence (e.g., monthly average rates or spot rates used).

I tell clients to assume you’ll be asked to reproduce any single year’s data within 48 hours. If you can, you’ll sleep better.

Do centralize your compliance calendar

Cross-border deadlines don’t align neatly. Build a calendar that includes:

FBAR (FinCEN) due April 15, with automatic extension to October 15.

U.S. tax returns and international forms due with the return; outbound information returns often carry separate penalties.

Corporate filings in each jurisdiction: annual returns, economic substance filings, VAT/GST.

Withholding returns (e.g., U.S. Forms 1042/1042-S) and remittances.

Beneficial ownership filings (e.g., U.S. Corporate Transparency Act reporting to FinCEN for many entities formed or registered to do business in the U.S.).

A missed zero-tax information return can cost more than the tax itself. Treat deadlines like payroll—immovable.

Do classify entities correctly

Determine whether foreign companies are corporations, partnerships, or disregarded entities for U.S. tax purposes. The “check-the-box” rules can help but have consequences.

Identify controlled foreign corporations (CFCs) and PFIC holdings early. CFC status triggers Subpart F and potential GILTI inclusions; PFICs trigger special rules for foreign funds.

Coordinate with local law. A trust in one jurisdiction may be treated as a corporation elsewhere. Don’t let a classification mismatch create double taxation.

Get this wrong and you can end up filing the wrong forms for years. Get it right and many downstream decisions become straightforward.

Do use real substance and governance

Put directors and key personnel where decisions actually occur. Keep minutes that reflect real business deliberation.

Maintain a local office where appropriate. If you rely on a registered agent’s mailbox, many banks will balk.

Align transfer pricing with reality. Document services, markups, and intercompany agreements.

Regularly review beneficial ownership and control definitions across jurisdictions.

Substance requirements aren’t just a box to tick. Banks, auditors, and tax authorities all look for coherent stories supported by documents.

Do plan before moving money

Dividends vs. salary vs. royalties carry different tax footprints and withholding rates.

Trigger points—like repatriating retained earnings—can create sudden tax bills if you haven’t accrued for them.

Evaluate treaty eligibility and limitation-on-benefits provisions before relying on reduced withholding. Keep the paperwork current.

A short “tax trail run” for a planned transaction often saves multiples in tax and advisory fees later.

Do choose investments with tax reporting in mind

U.S. taxpayers: avoid foreign mutual funds and ETFs unless you understand PFIC rules. If you must hold them, explore QEF or mark-to-market elections early and maintain annual statements.

Prefer funds that provide PFIC statements or U.S.-reporting share classes, or invest via U.S. brokers offering U.S.-domiciled funds.

For private placements offshore, request annual K-1 equivalents or PFIC reporting in subscription documents.

The simplest rule I share: if the investment promoter can’t explain your annual tax reporting in two minutes, pause.

Do leverage treaties and credits deliberately

Use the foreign tax credit to avoid double taxation, but match baskets correctly (general, passive) and track carryovers.

Check social security totalization agreements for cross-border employees or founders paying themselves.

Map the tie-breaker rules for dual-residents. Residence by treaty affects worldwide tax and reporting.

Treaties aren’t a magic shield; they’re a playbook. Read the plays with a competent advisor before game day.

Do work with qualified professionals—and coordinate them

Use specialists for foreign trust reporting, PFICs, transfer pricing, and voluntary disclosures. Generalists miss crucial details.

Make one advisor the “quarterback” to keep the full picture. Fragmented advice causes conflicting filings.

Ask for written scopes, fixed-fee components, and sample deliverables. Clarity upfront avoids surprises.

In my experience, clients who insist on a single integrated compliance plan pay less overall and catch issues earlier.

Do embrace withholding certificates and documentation

Keep W-8 and W-9 forms current for all payees and payors. Update on changes in circumstances.

For U.S. businesses paying foreign vendors, build a process for collecting W-8s and determining 30% withholding vs. treaty relief.

If you’re claiming treaty benefits, keep residency certificates on file.

Withholding mistakes create penalties for the payer and cash-flow pain for the payee. A clean onboarding checklist solves most of it.

Do use technology to your advantage

Use secure vaults for IDs, tax certificates, and entity documents.

Automate currency conversions and transaction categorization.

Maintain a live ownership chart and a compliance dashboard.

If you operate globally, select ERP and payroll systems that handle multi-currency and multi-jurisdiction rules natively.

Good systems turn compliance from a yearly fire drill into a monthly routine.

The don’ts

Don’t ignore “small” accounts or balances

FBAR applies when aggregate foreign account balances exceed $10,000 at any time during the year. One spike during the year counts. I’ve seen people miss FBARs because they only looked at year-end balances or a single account.

Don’t use nominees or straw owners

Putting assets in a relative’s name or using nominee directors is a fast track to willful penalty territory. Beneficial ownership rules are designed to see through that, and banks are trained to ask probing questions.

Don’t assume secrecy jurisdictions still provide cover

Jurisdictions once famous for secrecy now participate in CRS and enforce substance requirements. Your bank reports; your structure must make sense. If your plan depends on “no one will know,” you don’t have a plan.

Don’t skip information returns because “no tax is due”

Forms like 8938, 5471, 8865, 3520, and 8621 can carry penalties independent of tax due. The Supreme Court’s Bittner ruling limited non-willful FBAR penalties to per-form instead of per-account, but penalties still add up quickly.

Don’t mix personal and business funds

Co-mingling destroys credibility. It complicates tracing, creates taxable benefit issues, and makes audits painful. Open dedicated accounts and run expenses through the right entity from day one.

Don’t rely on banks or brokers to “handle the tax”

They handle their reporting. They don’t know your worldwide facts or tax status. I’ve seen U.S. expats rely on local bank advice for years and end up with PFIC exposure and missing forms.

Don’t self-certify tax residency casually

CRS and FATCA self-certifications feel like harmless paperwork. They’re not. Inconsistent information (addresses, phone numbers, country of birth, tax IDs) triggers reports to multiple jurisdictions and questions later.

Don’t “quietly” back-file without a strategy

Filing late returns and FBARs without a disclosure route can weaken your reasonable cause argument and shut doors. If you’re non-willful, the Streamlined Filing Compliance Procedures may be better. If you were willful, use the IRS Voluntary Disclosure Practice with counsel. Choose the path first; then file.

Don’t forget local-country reporting

A common trap: U.S. returns are perfect, but you missed a local filing—VAT returns, payroll reports, local ownership registers, or economic substance filings. Those lapses can freeze bank accounts and block dividends.

Don’t ignore currency gains and timing

Foreign currency gains on deposits, loans, or property can be taxable in the U.S., even if no cash profit exists in the local currency. Plan repatriations and conversions with currency in mind.

Don’t overreact

I’ve watched people shut accounts, transfer assets hastily, or dismantle entities mid-audit. Knee-jerk moves create more questions than answers. Fix the filings first, then optimize the structure thoughtfully.

Don’t set and forget

Residency, business models, and tax laws change. Reassess your structure annually. A quick “health check” each year avoids multi-year blind spots.

Forms and thresholds: a practical guide

This isn’t exhaustive, but it covers the forms I see most often for U.S. taxpayers. Always check the current instructions and thresholds.

FBAR (FinCEN Form 114): Required when the aggregate value of foreign financial accounts exceeds $10,000 at any time in the year. Includes bank, securities, certain insurance and pension accounts, and accounts you control or have signature authority over. Due April 15 with automatic extension to October 15. Penalties for non-willful violations can apply per form; willful violations are severe.

Form 8938 (Statement of Specified Foreign Financial Assets): Required for certain U.S. taxpayers with foreign assets above thresholds. For U.S.-based filers, typical thresholds start around $50,000/$100,000 for single/married filing jointly at year-end (higher for those living abroad). Unlike FBAR, it includes some non-account assets (e.g., interests in foreign entities).

Form 5471 (Information Return of U.S. Persons With Respect to Certain Foreign Corporations): Required for U.S. persons who are officers, directors, or shareholders in certain foreign corporations. Different categories trigger different schedules. Often the most time-consuming international form for small businesses.

Form 8865 (Return of U.S. Persons With Respect to Certain Foreign Partnerships): Similar to 5471 but for foreign partnerships. Includes controlled and certain 10% ownership thresholds.

Form 8621 (Information Return by a Shareholder of a Passive Foreign Investment Company): Required if you hold PFICs—often foreign mutual funds/ETFs and some foreign holding companies. Triggers complex tax and interest computations unless QEF or mark-to-market elections are made.

Forms 3520/3520-A (Annual Return to Report Transactions With Foreign Trusts and Receipt of Certain Foreign Gifts; Annual Information Return of Foreign Trust With a U.S. Owner): Used for foreign trusts and significant gifts or inheritances from foreign persons. Penalties for late or missing forms are steep.

Form 8858 (Information Return of U.S. Persons With Respect to Foreign Disregarded Entities): Required if you own a foreign single-member entity treated as disregarded.

Forms 1042/1042-S (Annual Withholding Tax Return for U.S. Source Income of Foreign Persons): For payers who withhold on U.S.-source income paid to non-U.S. persons. Often tied to W-8 series forms (W-8BEN, W-8BEN-E, W-8ECI, etc.).

Beneficial Ownership Information (BOI) reporting to FinCEN: Many U.S. entities formed or registered to do business in the U.S. must report beneficial owners and company applicants. Foreign-controlled U.S. entities may be in scope. Deadlines vary by formation date; penalties apply for noncompliance.

The biggest trap is overlap. FBAR and 8938 look similar but aren’t substitutes. Entity forms (5471/8865/8858) are separate from individual asset forms (8938/FBAR). When in doubt, build a matrix of assets/accounts/entities and tie each to the right form.

Special areas where people stumble

Foreign companies and CFC/GILTI

A foreign corporation becomes a controlled foreign corporation (CFC) when U.S. shareholders (each owning at least 10% vote or value) collectively own more than 50%. If you’re a U.S. shareholder of a CFC, you may need to include certain income currently:

Subpart F income includes passive categories and some related-party payments.

GILTI can capture active income above a routine return, with complex mechanics. Corporate U.S. parents often get deductions and indirect credits; individuals holding CFCs may consider a Section 962 election to mimic corporate treatment if they don’t already hold through a U.S. corporation.

High-tax exclusion or election can mitigate GILTI when foreign effective tax rates exceed thresholds, but documentation matters.

I’ve seen founders surprised by GILTI after a profitable year abroad despite no cash distributions. Modeling ahead avoids unexpected U.S. tax or lets you restructure.

PFICs and foreign funds

Holding a foreign mutual fund, ETF, or certain investment companies often triggers PFIC status:

Without a QEF or mark-to-market election, “excess distributions” get taxed at the highest rates with an interest charge across prior years.

QEF requires the fund to provide annual PFIC statements—rare unless the fund targets U.S. investors.

Mark-to-market can simplify annual reporting for marketable securities but locks in ordinary income treatment and can be painful in down years.

Example: A U.S. expat buys a popular local ETF through a non-U.S. broker. After five years, the fund doubled. Without elections, a sizable chunk of the gain is treated as prior-year distributions with punitive interest. If the same exposure were held via a U.S.-domiciled ETF, the PFIC rules wouldn’t apply.

Foreign trusts and “helpful” family planning

Foreign trusts are highly fact-specific:

U.S. owners and U.S. beneficiaries face extensive reporting (3520/3520-A) and potentially the “throwback” rules on accumulations.

Seemingly simple arrangements—like family foundations, education trusts, and corporate nominees—can be trusts by substance.

Trustees should provide annual U.S.-friendly statements. If they can’t, the U.S. beneficiary bears the complexity.

I’ve unwound more well-meaning but poorly documented family structures than aggressive tax schemes. Clarity beats creativity here.

Crypto on offshore exchanges

Rules are evolving. Some offshore platforms report under FATCA/CRS, some don’t. Virtual currency is property for U.S. tax purposes, but whether accounts on foreign exchanges trigger FBAR/8938 depends on technical definitions that are still being refined. My practical view: lean toward disclosure (especially for fiat-linked accounts and custodial wallets) and maintain complete trade and wallet records. Also watch new broker reporting rules as they phase in.

Real estate abroad

Directly owning foreign real estate doesn’t trigger FBAR or 8938 by itself, but mortgages and rental accounts often do.

Local taxes, stamp duties, and notary fees can be substantial. Track them for basis and foreign tax credits.

Rental income means local filings, sometimes withholding. If you use a local company or trust to hold property, expect more U.S. forms.

Expatriation and exit tax

Renouncing U.S. citizenship or abandoning a green card can trigger an exit tax for “covered expatriates.” Tracking five years of compliance is key; Form 8854 certifies it. If you’re contemplating expatriation, get advice at least a year in advance to manage timing, gifts, and entity restructures.

Transfer pricing for growing businesses

Intercompany charges for services, IP, and financing must reflect arm’s-length terms.

Many countries require contemporaneous documentation and local filings (master/local files).

For start-ups, a simple services agreement and cost-plus model helps. As you grow, revisit your policy yearly.

Even small intercompany flows get scrutiny when profits cluster in low-tax entities without headcount or decision-makers.

Withholding and treaty claims

The default U.S. withholding on many passive payments to non-U.S. persons is 30%. Valid W-8 forms and treaty eligibility reduce it.

Limitation-on-benefits (LOB) provisions can block treaty access if you don’t meet ownership and activity tests.

For U.S. businesses paying foreign vendors or contractors, classify services performed in the U.S. carefully; those may be ECI, not FDAP, changing the withholding and reporting regime.

When you onboard a foreign payee, ask: who are we paying, what for, where is it performed, and do we have the right forms? That avoids year-end chaos.

Getting compliant if you’re late

I’ve helped many people clean up back years. The key is to slow down, assess willfulness carefully with counsel, and pick the right path.

Step 1: Confidential diagnostic

Inventory all foreign accounts, entities, and income for the open years (typically six years for FBARs, three-plus for returns).

Pull bank statements and evidence of tax paid abroad.

Identify missing forms and potential penalty exposure.

Do this under attorney-client privilege if there’s any risk of willfulness.

Step 2: Choose a pathway

Streamlined Filing Compliance Procedures (SFCP): For non-willful taxpayers. Generally requires three years of amended or delinquent returns, six years of FBARs, and a non-willfulness certification. The domestic version typically involves a 5% miscellaneous offshore penalty; the foreign version may have no penalty. Eligibility is critical—don’t assume.

IRS Voluntary Disclosure Practice (VDP): For willful or high-risk cases. Involves preclearance, extensive disclosure, and negotiated penalties. You’ll need legal representation.

Reasonable cause filings: Possible when you have a strong, documented reason for missing information returns. The IRS has narrowed leniency over time; results vary.

Do nothing: Occasionally appropriate if statutes closed and risk is minimal, but this is rare and should be a deliberate, informed decision.

Step 3: Execute cleanly

Prepare accurate amended returns and FBARs, with consistent narratives.

Reconstruct missing basis and currency conversion data methodically—better a conservative documented estimate than a guess.

Pay what’s due and request penalty relief where justified.

Step 4: Stabilize the present

Fix entity classifications and bank documentation.

Set up your compliance calendar and record-keeping system.

Educate your internal team or family office on recurring obligations.

Clients who try to “be quick” often make sloppy filings that undermine their narrative. Precise, consistent, and well-documented beats fast.

Building a practical offshore compliance program (for businesses)

You don’t need a big-four team to run a tight ship. Focus on five pillars:

Ownership and governance clarity

Maintain a current org chart with ownership percentages, director/officer lists, and control points.

Document decision-making: who approves what, where meetings occur, and how minutes are kept.

Policy and procedures

Write a lean international tax and withholding policy: entity purposes, transfer pricing, documentation standards, W-8/W-9 onboarding, and reporting deadlines.

Include a CRS/FATCA self-certification process with verification.

Data and systems

Centralize contracts, tax IDs, certificates of residency, and filings in a secure, searchable repository.

Tag payments with tax character (royalty, service, interest) at the ERP level to drive withholding logic.

Calendar and accountability

Maintain a single master calendar for all jurisdictions.

Assign RACI (Responsible, Accountable, Consulted, Informed) for each filing and payment.

Review and adapt

Conduct an annual cross-border health check: substance, transfer pricing, treaty usage, and structure fit for business changes.

Update W-8/W-9s on change of circumstances.

The best small-company programs run on a one-page policy, a live org chart, a spreadsheet calendar, and disciplined documentation.

Common mistakes and how to avoid them

Owning foreign funds through a local broker: Switch to U.S.-domiciled funds or get PFIC statements. If already held, explore mark-to-market and clean up early.

Using foreign single-member companies without 8858: File late with reasonable cause if eligible; then calendar it annually.

Missing 5471 for “small” ownership: Reassess ownership including attribution rules (spousal and family). If you cross thresholds mid-year, filing may still be required.

Treating foreign pensions like U.S. IRAs: Confirm treaty treatment. Some foreign pensions are taxable annually in the U.S.; contributions may not be deductible.

Ignoring signature authority FBARs: Corporate officers with signatory power often have FBAR obligations even without ownership.

Over-claiming foreign tax credits: Match income categories correctly and avoid claiming credits for non-creditable levies (e.g., some stamp duties).

Quiet disclosures after receiving a compliance letter: Once the IRS contacts you, streamlined options often close. Consult counsel immediately.

Misusing check-the-box elections: Consider local anti-hybrid rules and exit tax on “deemed liquidations.” Coordinate with local advisors.

Missing 1042/1042-S filings: U.S. payers to foreign persons often skip withholding regimes. Set a vendor onboarding protocol and engage a withholding agent or software.

A 90-day playbook to get right

Days 1–7: Build your footprint map. List all accounts, entities, and income streams. Secure online access and download annual statements.

Days 8–21: Hold a diagnostic session with a cross-border tax advisor. Identify forms required and exposure by year. Decide on disclosure path if late.

Days 22–45: Assemble records. Reconstruct missing basis with broker letters and transaction histories. Obtain tax residency certificates if needed for treaty claims.

Days 46–60: Prepare returns and information forms. Draft non-willfulness certifications or VDP submissions if applicable. Align FBAR/8938 with entity forms.

Days 61–75: File or submit preclearance as needed. Pay balances due. Set up an installment agreement if helpful.

Days 76–90: Implement calendar, documentation protocols, and bank form updates. Adjust investment choices (e.g., PFIC exposure) and entity classifications as needed. Schedule an annual review.

This sprint transforms compliance from reactive to proactive and reduces next year’s work.

Quick checklists

Individuals

Do I have any foreign bank, brokerage, pension, insurance, or crypto exchange accounts?

Did my aggregate foreign account balance ever exceed $10,000?

Do I own shares in a foreign company, an interest in a foreign partnership, or a foreign single-member company?

Do I hold any foreign mutual funds, ETFs, or structured products?

Have I received foreign gifts or distributions from foreign trusts?

Did I move money between countries, change tax residency, or spend significant time abroad?

Are my W-8/W-9s, residency certificates, and self-certifications up to date?

Have I aligned FBAR, 8938, and entity forms across years?

Businesses

Do we have a current org chart and beneficial ownership list?

Do we have intercompany agreements and a transfer pricing policy?

Are W-8/W-9s collected and validated for all relevant payees? Are treaty claims documented?

Are 1042/1042-S filings, state nonresident withholding, and similar obligations on the calendar?

Are foreign corporate filings, substance reports, and VAT/GST returns up to date?

Have we determined CFC/PFIC exposures for owners and provided them the data they need?

Is our policy for crypto, digital assets, and emerging products documented?

Practical examples from the field

The expat with a local ETF: A U.S. citizen moved to Germany and invested €150,000 in local ETFs. After four years, gains were significant. We modeled three options: hold and accept punitive PFIC treatment; switch to mark-to-market with a one-time adjustment; or rebuild exposure via U.S.-domiciled ETFs. The client chose a phased exit, spreading PFIC pain across two years with estimated taxes and moving future savings to U.S.-domiciled funds.

The start-up with a foreign dev team: A Delaware C-corp set up a wholly owned subsidiary in Poland. They paid intercompany costs ad hoc. We implemented a cost-plus-10% services agreement, documented substance, and prepared 5471 filings. The CFO credited the clean structure for smooth Series A diligence.

The family trust mystery: A client received distributions from a “family foundation” in Latin America. It was effectively a foreign trust. We obtained trustee statements, filed 3520/3520-A, and educated the family about the throwback rules. Going forward, distributions were set on a current-year basis to eliminate punitive accumulation tax.

Working with advisors: questions to ask

What percentage of your work involves cross-border reporting like 5471/8865/8621/3520? Can you share anonymized examples?

How do you coordinate with local-country advisors?

What’s your plan if we’re late—streamlined, reasonable cause, or voluntary disclosure? What are the tradeoffs?

How will you document entity classification decisions and treaty positions?

How do you ensure consistency across FBAR, 8938, and entity forms?

Can we fix fees for the recurring components so there are no surprises?

An advisor who welcomes these questions usually runs a sound process.

A balanced mindset

Offshore compliance isn’t about fear or avoidance; it’s about clarity. The systems now in place favor those who organize early, document thoughtfully, and keep filings consistent with what banks and counterparties report. The right approach blends discipline—clean records, tight calendars, thoughtful entity choices—with practical flexibility as life and laws evolve.

If you remember nothing else, remember this: map your footprint, pick investments and structures you can report cleanly, and build a small routine you repeat every year. That routine is what protects you when the notices start flying or when an investor’s diligence team opens the hood.