Form 8832 Check-the-Box Entity Elections Under Section 7701: Selecting Entities for Foreign Operations
Note: CLE credit is not offered on this program
Recording of a 110-minute CPE webinar with Q&A
This course will provide tax advisers with practical guidance on the advantages and pitfalls of utilizing the check-the-box entity selection for U.S. individuals with offshore business activities. The panel will discuss the various tax effects of specific elections, outline the tax timing and treatment, and explain repatriation and the implications of entity selection on tax treatment.
Outline
- The U.S. Check-the-Box Regulations - Background
- Basic Entity Classification Rules for Foreign Entities owned by U.S. Persons
- The Greatly Increased U.S. Tax Stakes for US Persons in Selecting the FORM of a Foreign Entity
- Advanced Tax Considerations (and Modeling) in Foreign Entity Selection Process
- Completing IRS Form 8832 and late elections
- Advanced Entity Selection considerations in light of Recently finalized U.S. Anti-Hybrid §267A Regs and foreign anti-hybrid rules
Benefits
The panel will discuss these and other vital issues:
- The implications of using check-the-box elections to pull foreign-source income out of Subpart F treatment
- Retroactive entity selection and completing Form 8832
- How to determine whether a foreign entity is relevant for U.S. taxation purposes
- The impact of tax law changes on check-the-box elections and tactics to maximize tax savings
Faculty

Pamela A. Fuller, Esq., J.D., LL.M. (Taxation)
Senior Counsel (Tax, M&A, International)
Tully Rinckey PLLC and Zahn Law Group
Ms. Fuller’s practice has a triple focus: tax planning, tax controversies, and tax compliance. She advises a wide... | Read More
Ms. Fuller’s practice has a triple focus: tax planning, tax controversies, and tax compliance. She advises a wide range of clients–including private and public companies, joint ventures, funds, high-net-worth individuals, C-Suite executives, and government entities–on transactional, investment, and supply-chain strategies to achieve optimal tax and business results. Ms. Fuller advises clients on both purely domestic transactions and transnational ones, helping both U.S.-based companies and foreign companies (and their executives) achieve the best possible results from a tax and business perspective. Ms. Fuller is Chair of the ABA’s Tax Section’s Tax Policy Committee, and also Co-Chair of the International Tax Committee of the ABA’s worldwide International Law Section. She frequently speaks at law conferences, and publishes papers on international tax topics in peer-reviewed law journals.
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Ronald Kalungi, JD, LLM
Director of International Tax
Drucker & Scaccetti
Mr. Kalungi provides tax planning, tax compliance and business consulting services to a broad base of clients including... | Read More
Mr. Kalungi provides tax planning, tax compliance and business consulting services to a broad base of clients including multinational corporations, partnerships, S Corporations, and high-net-worth individuals.
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