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Foreign owners of domestic corporations and foreign corporations engaged in U.S. trade or business may need to file Form 5472. Complex attribution rules make identification of reporting requirements difficult. Learn when Form 5472 is required, the types of attribution rules that apply, and major issues to report.
Presenter: Debra Rudd
Materials: Dropbox
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Foreigners buy U.S. houses for personal use. But how should they own those properties? In this session, Phil Hodgen explains the estate tax and capital gain tax performance of eight different methods of holding title, from direct ownership to irrevocable trusts.
Presenter: Philip Hodgen
Materials: Dropbox
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Everyone “knows” that tax treaties can be used to solve tax problems. But how, exactly, do you figure out whether a tax treaty is useful in your case? Receive guidance on using income tax treaties and more in this course.
Attendees will consider how do you prepare Form 8833 to claim the treaty benefits. Plus, determine the impact of claiming treaty benefits on the tax return paperwork and identify whether your income tax is a liability.
Presenter: Phil Hodgen
Materials: Dropbox
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In this presentation, trace the evolution of the U.S. owners’ filing requirements with respect to a foreign startup company over the years as more U.S. owners buy in and the total U.S. ownership increases.
Examine the Form 8621 and Form 5471 filing requirements for each year for each of the US individuals involved. Cover how to make a purging election to tax the startup as a CFC (and not a PFIC) in the final year. Finally, briefly discuss the option of making a QEF election for the pre-CFC years.
Presenter: Deba Rudd
Materials: Dropbox
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The Foreign Investment in Real Property Tax Act (FIRPTA) requires tax withholding when a foreign person transfers real property interest in the U.S. Learn what the withholding requirements are and how to meet them.
Presenter: Debra Rudd
Materials: Dropbox
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