Archive: foreign corporation

  • Clear Filters

U.S. Individual Shareholders of Controlled Foreign Corporations May Elect to Decrease Tax on GILTI

The Tax Cuts and Jobs Act (TCJA) enacted various U.S. international tax provisions. The new law includes the U.S. federal tax on global intangible low-taxed income referred to as GILTI. The GILTI rule applies to U.S. shareholders of controlled foreign corporations (CFCs). Effective on January 1, 2018, a U.S. shareholder of a CFC is required […]

U.S. Shareholders of Foreign Corporations and the Moving Target of Form 5471

The 2017 Tax Cuts and Jobs Act (TCJA) enacted significant changes to the U.S. international tax regime. U.S. shareholders are affected by the changes that impact the U.S. tax consequences of owning a foreign corporation. The TCJA revised the technical rules applicable to U.S. shareholders of controlled foreign corporations (CFCs). Along with issuing guidance on […]

Alison Dougherty Hosted a Webinar on Form 5471 – Interests in Foreign Entities After Tax Reform

Alison Dougherty, a director in Aronson’s Tax Services Group, hosted a webinar titled, “Form 5471 for Interests in Foreign Entities After Tax Reform,” on June 12th. The webinar provided tax advisers with a practical guide to completing the new Form 5471, Information Return of U.S. Persons With Respect to Certain Foreign Corporations. The panel detailed the […]

A U.S. Owner of a Foreign Corporation May Need to Report the U.S. Repatriation Tax on the 2017 U.S. Federal Income Tax Return

There was new U.S. international tax legislation enacted in the Tax Cuts and Jobs Act in December 2017. The new law requires a U.S. shareholder of a foreign corporation to pay U.S. federal tax on the undistributed offshore earnings of the foreign corporation. What is the U.S. repatriation tax? Certain U.S. shareholders of a foreign […]

Key U.S. International Tax Provisions in the New Tax Legislation

The new U.S. Federal tax legislation includes some important revisions to the U.S. international tax rules. These rules are applicable to U.S. taxpayers with outbound cross-border activities in other countries. The following are some important highlights that could have an impact on the U.S. Federal tax obligations beginning as of January 1, 2018. 100% U.S. […]

New Form 5472 Filing Requirement for U.S. Disregarded Entities Owned by a Foreign Person

On December 13, 2016, the IRS issued T.D. 9796, new regulations that require U.S. disregarded entities owned by a foreign person to file U.S. Federal Form 5472. The new Form 5472 filing requirement applies for tax years beginning after December 31, 2016 and ending on or after December 13, 2017. Form 5472 is required to […]

Tax Considerations for Outbound Transfers of Intangible Property Offshore

There are some important U.S. international tax considerations to be aware of when a U.S. person transfers intangible property outside the United States. When a U.S. person contributes intangible property to a foreign corporation as a capital contribution in exchange for stock, a taxable event will generally occur for U.S. federal income tax purposes. The U.S. transferor […]

International Tax Series: Be Aware of the Form 5471 Filing Requirement if a U.S. Person Owns Stock in a Foreign Corporation

The Form 5471 may need to be filed if a U.S. person owns an interest in a foreign corporation.  A foreign entity is required to be classified as a foreign corporation for U.S. tax purposes if the foreign entity is on the U.S. list of per se foreign corporations.  The list of per se foreign […]