Foreign Entity Selection for U.S. Owners of Offshore Businesses: Avoiding Tax and Reporting Traps
Applying U.S. Law to Foreign Structures, Determining Whether Foreign Trust Qualifies for U.S. Treatment
A live 110-minute CPE webinar with interactive Q&A
This webinar will provide tax advisers to individuals owning controlling shares in foreign businesses with a practical guide to the tax and operational impacts of selecting the entity form for those foreign entities. The panel will discuss the full range of short-term and long-term tax issues that arise in foreign entity selection, with a specific focus on the changes the 2017 tax reform law made on U.S. tax consequences in selecting the appropriate entity form for purposes of U.S. tax treatment of offshore holdings.
- IRS rules detailing jurisdiction over classification of foreign business organizations owned by a U.S. taxpayer
- Determining if a foreign business organization or activity qualifies as a taxable entity separate from its U.S. owner
- Treas. Reg. 301.7701-4(a)-(c) trust definitions and rules
- Tax treatment of foreign business entities
- Available elections
The panel will discuss these and other relevant topics:
- Applying fact analysis to determine 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 "relevant" and thus subject to U.S. tax or informational reporting requirements
- How treatment of the foreign entity in its home country can complicate the decision on entity selection/classification
- Available elections to determine 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
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