Form 5472 Information Return of a 25% Foreign-Owned U.S. Corporation or a Foreign Corporation Engaged in a U.S. Trade or Business is often an overlooked form. In general, this form has been required if the reporting corporation had a reportable
The Bipartisan Budget Act (“Act”) was signed into law on November 2, 2015 amending the rules concerning how entities taxed as partnerships will be audited by the IRS and who is required to pay the tax resulting from audit adjustments.
Normally, under Internal Revenue Code § 61(a)(12), income from the discharge of indebtedness is includable in gross income, however, such income may be excludable from gross income under certain exceptions found in Internal Revenue Code § 108. § 108(a)(1)(A) and
Under current regulations, spanning from Treas. Reg. §§ 301.7701-1 through 301.7701-3, a domestic limited liability company (“LLC”) organized under the laws of the United States, with only one member is by default classified as a disregarded entity for tax purposes.
Pursuant to Internal Revenue Code § 1361, there are certain restrictions to qualify for S-Corporation status; one of which is that a shareholder cannot be a nonresident alien. If a nonresident alien were to become a shareholder of an S-Corporation