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Figuring out Categories 5a/5b/5c, in five installments I want to help you figure out which box to check (or not!) in Item B of Form...

This topic is from real life, and will help you this tax season when confronted with a holding structure that looks like the one discussed...

This is a lengthy discussion of a common fact pattern: When does a U.S. citizen spouse have a Form 5471 filing requirement, merely by being...

Form 5471 is hard because, among other reasons, you have to figure out the meaning of the word "own." There's your understanding of the word....

Shameless Pimping The first of eleven episodes of The Form 5471 Series will go live next Friday, April 28, 2023, at noon Pacific time. People...

Update, Prophesy, and Exhortation This week's post is shorter than usual. I deliver here an Update, a Prophesy, and an Exhortation. Update. A very recent...

In our last thrilling episode of The Form 5471 Files, we considered the curious case of a U.S. manufacturer that sold widgets to its lower-tier...

When will a CFC's regular-looking business income from regular-looking, normal business operations be classified as Subpart F income? This week I introduce the concept of...

We need to identify the shareholders of a "reporting corporation" and if we find one or more "25% foreign shareholders" they are listed in Form...

Introduction We have default assumptions about everything. "Unless proven otherwise, X is true." For U.S. taxpayers who own stock of controlled foreign corporations, the default...

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...

On July 10, 2020 I will  present a live Section 962 webcast that goes into excruciatingly painful detail about preparing a Section 962 tax return....

Introduction All of the profits generated by a minimultinational enterprise will be exposed in real time to the U.S. tax system. Chapter 2 explains why....

American minimultinationals are small (for various definitions of "small") business enterprises subjected to the U.S. tax system. There are many ways that a minimultinational becomes...

What's an American Minimultinational? What do I mean by American minimultinational? Multinational A multinational business operates in multiple countries, exposed to multiple tax-hungry governments. Apple....

The Tax Cuts and Jobs Act completely rewrote Section 965 to force a one-time repatriation of deferred earnings and profits in foreign corporations. It forces...