Foreign Entity Selection and Taxation: Avoiding Tax and Reporting Pitfalls of Foreign Structures Under U.S. Law
Planning for U.S. Owners of Offshore Businesses, Treatment of Foreign Trusts and Other Entities
Recording of a 90-minute premium CLE/CPE webinar with Q&A
This CLE/CPE course will provide tax counsel and advisers an in-depth analysis of the tax and operational impacts of foreign entity selection for individuals owning controlling interests in international businesses. The panelist will discuss the tax issues that arise in foreign entity selection, with a specific focus on the U.S. tax consequences in selecting the appropriate entity form for purposes of U.S. tax treatment of offshore holdings under current U.S. tax law.
- IRS rules for foreign entity classification for U.S. taxpayers
- Determining if a foreign business organization or activity qualifies as a taxable entity separate from its U.S. owner
- Trust definitions and rules under Treas. Reg. 301.7701-4(a)-(c)
- Tax treatment of foreign business entites and available elections
The panelist will review these and other relevant topics:
- Key considerations in determining whether to classify a foreign situs trust as a trust for U.S. tax purposes or risk recharacterization as a taxable business entity
- Identify when a foreign entity becomes subject to U.S. tax or informational reporting requirements
- How can the treatment of the foreign entity in its home country complicate the decision on entity selection/classification?
- Available elections and planning to ensure favorable U.S. tax classification of foreign business entities
Patrick J. McCormick, J.D., LL.M.
Drucker & Scaccetti
Mr. McCormick specializes in the areas of international taxation, tax compliance, and offshore reporting... | Read More
Mr. McCormick specializes in the areas of international taxation, tax compliance, and offshore reporting obligations. He published national articles and given numerous national and local presentations on assorted areas of tax and estate planning law, including international tax and offshore compliance issues. His latest article on PFICs is titled Tax Reporting Implications of Foreign Mutual Funds. He is licensed to practice in the States of New Jersey, Florida, and Georgia, and the Commonwealth of Pennsylvania.Close