Check-the-Box Elections as an Anti-Form 5471 Damage-Control Technique
The Scenario A nonresident owns 100% of the stock of a foreign corporation, which holds highly appreciated foreign real estate. The nonresident plans to become a U.S. resident (and therefore taxpayer) starting on January 1, 2024. He wants to keep the real estate, and for tax and expense reasons in his home country, dissolving the…