Form 8858 Reporting of U.S. Owned Foreign Disregarded Entities: Ownership and Correct Filing Status
Information Return Requirements for Check-the-Box Structures Including Indirect and Constructive Ownership
Recording of a 110-minute CPE webinar with Q&A
This webinar will provide tax advisers with guidance to the U.S. reporting requirements for ownership of foreign disregarded entities (FDREs) on IRS Form 8858. The panel will offer section-by-section detail on completing Form 8858, discuss the interrelation between Form 8858 and other required international information reporting, and review IRS enforcement practices and actions through their filing checks/matching examination process.
- Classification of FDREs
- Definition for U.S. tax purposes
- Examples of foreign structures
- Check-the-box elections and impact on Form 8858 filing requirements
- Types of ownership
- Critical sections of Form 8858 which lead to IRS scrutiny
- Intersection with Forms 5471 and Form 8865
- Penalties for noncompliance
The panel will discuss these and other important questions:
- Identifying Form 8858 reporting obligations from Form 5471 and Form 8865 filings
- Recognizing the types of ownership of FDREs and how indirect or constructive ownership impacts which sections of Form 8858 must be completed
- Penalties involved in Form 8858 noncompliance
- Completing the individual sections of Form 8858
Alison N. Dougherty, J.D., LL.M.
Ms. Dougherty has extensive experience assisting clients with U.S. tax reporting and compliance for offshore assets and... | Read More
Ms. Dougherty has extensive experience assisting clients with U.S. tax reporting and compliance for offshore assets and foreign accounts. She specializes in international tax compliance, planning and structuring as a subject matter leader of her firm's international tax practice. Her responsibilities include U.S. Federal and multi-state tax compliance for C corporations, S corporations, partnerships and individuals. She also provides transactional tax planning and structuring services.Close
C. Edward Kennedy, Jr., CPA, JD
C. Edward Kennedy Jr.
Mr. Kennedy has more than 36 years of experience dealing with a variety of international tax matters, specializing in... | Read More
Mr. Kennedy has more than 36 years of experience dealing with a variety of international tax matters, specializing in tax consulting services to a wide variety of clients ranging from closely held companies to multi-national businesses. His expertise includes domestic and foreign income and social security tax planning, tax compliance for individuals and corporations, tax treatment of incentive compensation plans, international assignment program administration, and international assignment policy design. He has also served as the U.S. practice leader for international social security matters for a Big 4 accounting firm.Close