News & Analysis as of September 20, 2024

Income Taxes › Foreign-Owned Corporations

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Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect income taxes based on a progressive scheme, while others may utilize a proportional or regressive framework. less -

[Webinar] Preparing Form 5472 step by step instructions - February 22nd, 12:00 pm - 2:00 pm CT

Freeman Law on 2/18/2022

You are invited to Freeman Law Tax Academy Series - FORM 5472: STEP BY STEP INSTRUCTIONS - Learning Objectives: - Determine the applicability of Form 5472 - Properly complete Form 5472 - Identify prospective...more

Thoughts about the New Filing Requirements for Foreign-Owned U.S. entities?

Foodman CPAs & Advisors on 6/11/2018

Foreign Persons that own 25% of a US entity might want to reassess their strategy as it relates to that ownership. It “used to be” (until December, 2016) that a Foreign Person as a single owner of a Limited Liability Company...more

New Reporting Requirements For Foreign-Owned Disregarded Entities Have Taken Effect

Akerman LLP on 2/21/2018

The final regulations enacted in late 2016 that impose new reporting requirements on foreign-owned disregarded entities have now taken effect, bringing changes that will add significant complexity for many taxpayers this tax...more

Prepare Now for 2018 Reporting of Foreign-Owned U.S. Disregarded Entities

McGuireWoods LLP on 11/20/2017

Late last year, the U.S. Treasury imposed new information reporting obligations on certain foreign-owned U.S. “disregarded” entities — that is, certain U.S. entities that are wholly owned by one non-U.S. person so they are...more

Newsflash: Tax Court Reverses IRS Revenue Ruling

Dechert LLP on 7/19/2017

A recent U.S. Tax Court case, Grecian Magnesite (149 T.C. No. 3, July 13, 2017), has declared invalid the long-standing U.S. government position that a non-U.S. person’s sale of an interest in a partnership (in this case, a...more

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