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Limited Liability Company (LLC) Foreign-Owned Corporations

Foodman CPAs & Advisors

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

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

Farrell Fritz, P.C.

Information Reporting For The Foreign-Owned Not-So-Disregarded Disregarded Entity

Farrell Fritz, P.C. on

As the taxable year ending December 31, 2017 approaches, the thoughts of most people turn to holidays and family gatherings, feasting and celebrations, and reflecting, perhaps, on another year gone-by. Not so for tax...more

McGuireWoods LLP

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

McGuireWoods LLP on

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

Dechert LLP

Newsflash: Tax Court Reverses IRS Revenue Ruling

Dechert LLP on

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

Manatt, Phelps & Phillips, LLP

One-Two Punch for Transparency: Beneficial Owners Outed

In an apparent effort to create the impression of strong U.S. policy response in the wake of the Panama Papers, the U.S. Department of the Treasury (Treasury) announced three initiatives to promote greater transparency and...more

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