The Scenario A nonresident owns 100% of the stock of a foreign corporation, which holds highly appreciated foreign real estate. Real estate FMV $4,000x, basis...
This article looks at Category 2 filers. These are United States persons serving as officers and directors of foreign corporations. The lesson of this post...
Form 5471 exists because Subpart F (IRC §§951-965) exists. Or to be more precise, Form 5471 exists because Subpart F exists and taxpayers are smarter...
One favorite way to wiggle out of any responsibility is to mooch off someone else's hard work. Form 5471 filing is no exception. Go look...
Legal Authority This method of joint filing for Category 2 filers is described in Reg. §1.6046-1(e)(3). Introduction Start With the Filing Requirement Trigger Start with...
Here is a simple explanation of "tested interest expense" -- one of the variables you will compute when calculating how much global intangible low-taxed income...
We are currently seeking an International Tax Attorney, either part time or full time.
Click for more deatils >>