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 […]
Obtaining EIN for Form 5472: Is ITIN Mandatory for “Responsible Party”?
Category: Form 5471 and Form 5472
Reporting Rules Now Apply to Disregarded Foreign-Owned US LLC
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 […]
Your “Loan” to a Foreign Corporation
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 […]
Expatriation SNAFU! Form 5471 Not “Substantially Complete”
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 […]
Bad Dream: Form 5471….. Nightmare: Getting It Wrong
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 […]
Damage Control: US Works to Repair Its “Tax Haven” Reputation
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 […]
Disregarded Entity – Ownership of Foreign Real Property
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) […]
More Guidance from IRS: Final Regs and Specified Foreign Financial Assets / Form 8938
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 […]
The IRS Will Soon Be Asking Questions, PART II: Nominees and FATCA
FATCA and the Nominee Part I of this post can be found here. By brief background, under FATCA, foreign financial institutions (FFIs) must agree to verification and due […]
The IRS Will Soon be Asking Questions PART I — Nominees and FATCA
In my tax practice in the Middle East, it is very common for family members to have legal title to assets they do not own. For example, it […]