Head’s Up! Foreign-Owned Single Member US LLC: Increase in Penalties for Form 5472

My earlier blog post covered some basics about Form 5472, including how the Form helps the US Internal Revenue Service (IRS) learn about foreign-owned businesses in the US and when to audit them, the meanings of certain terms such as what is meant by a “reportable transaction” with a “related party”, and the situation requiring filing … Continue reading Head’s Up! Foreign-Owned Single Member US LLC: Increase in Penalties for Form 5472 →

Real Life Examples: A US Tax Mess, International Community Property

Attention all mixed nationality couples, with one spouse having US citizenship or US resident status while the other is a nonresident alien (NRA)! Your tax advisor should be looking at all possible issues surrounding your fact pattern. If you live in a foreign jurisdiction or US state (there are 9 of them) with a community … Continue reading Real Life Examples: A US Tax Mess, International Community Property →

Form 5472 – Everything You Need To Know (Part I)

This tax filing season brought a wave of questions about Form 5472. Interest in this complex form was renewed because of recent Treasury Regulations requiring that it be filed by single-member US LLC’s that are foreign owned. Prior to the issuance of these regulations, a single member foreign-owned US LLC was treated as a tax … Continue reading Form 5472 – Everything You Need To Know (Part I) →

Form 5472 – Everything You Need To Know (Part II)

Last week’s blog post covered some basics about Form 5472, including how the Form helps the US Internal Revenue Service (IRS) learn about foreign-owned businesses in the US and when to audit them, the meanings of certain terms such as what is meant by a “reportable transaction” with a “related party”, and the situation requiring filing of … Continue reading Form 5472 – Everything You Need To Know (Part II) →