Last week’s blog post covered some basics about Form 5472, including how the Form helps the US Internal Revenue Service (IRS) learn about foreign-owned businesses in the US […]
Form 5472 – Everything You Need To Know (Part II)

Last week’s blog post covered some basics about Form 5472, including how the Form helps the US Internal Revenue Service (IRS) learn about foreign-owned businesses in the US […]
This tax filing season brought a wave of questions about Form 5472. Interest in this complex form was renewed because of recent Treasury Regulations requiring that it be […]
As many of my readers are likely aware, commencing with the 2017 tax year, single-member US LLC’s with foreign ownership will need to file Form 5472 to […]
The US Internal Revenue Service (IRS) recently published final regulations (the “Regulations”) under section 6038A of the Internal Revenue Code that address reporting and recordkeeping obligations of US […]
What happens if you make a loan to a foreign (non-US) corporation and the Internal Revenue Service (IRS) later determines that the “loan” should not be treated as […]
My earlier blog posting covered some of the basics of Form 5471, “Information Return of U.S. Persons with Respect to Certain Foreign Corporations”. The Form is notoriously complex […]
Since 2009, an ever increasing emphasis has been put on international tax compliance, with stiff penalties being imposed by the Internal Revenue Service (IRS) if things are not […]
On March 30th, the US Treasury Department announced that proposed Treasury regulations will soon be issued requiring foreign-owned, single-member limited liability companies (LLCs) created in the USA to […]
Part I of this blog post discussed the general concept of what is called a “disregarded entity”. It also examined how the “disregarded entity” is used (and misused) […]
Further guidance was just provided by the IRS in the form of finalized Treasury Regulations for those individuals who are required to report interests in so-called “specified foreign […]