Shareholders in Closely-Held Foreign Corporations: Beware Form 5471
Posted on: October 8, 2018 | By: Stephen Dunn | Controlled Foreign Corporations, Delinquent International Information Return Submission Procedures, Foreign Accounts Compliance, Form 5471, International Information Returns, Uncategorized
A U.S. taxpayer whose interest in a closely-held foreign corporation meets a specified threshold must file Form 5471, Information Return of U.S. Persons With Respect to Certain Foreign...
Why Congress Cannot Tax the Undistributed Earnings of U.S. Corporations’ Foreign Subsidiaries
Posted on: September 20, 2017 | By: Stephen Dunn | Controlled Foreign Corporations, U.S. Corporations' Foreign Subsidiaries
The United States does not tax a parent corporation on the earnings of its subsidiary until the subsidiary distributes the earnings to the parent as a dividend. This...