Form 8865: Reporting Foreign Partnership Interests
Determining Taxpayer Categories Based on Control or Ownership, Calculating Allocable Share of Foreign Income and Tax Basis Capital
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 and return preparers with a practical guide to completing Form 8865, Return of U.S. Persons with Respect to Certain Foreign Partnerships. The panel will discuss how to correctly identify the taxpayer category, determine the allocable share of foreign income, comply with tax basis capital reporting requirements, and how to avoid potentially costly mistakes.
Outline
- Purpose of Form 8865
- Categories of taxpayers subject to Form 8865 filing requirements
- Category 1: Control (50 percent test)
- Category 2: U.S. controlled partnership
- Category 3: Contribution of property to a foreign partnership
- Category 4: Other filing requirements
- Preparation of Form 8865
- Tax basis capital reporting
- Schedules
- Difficult compliance issues related to Form 8865
- IRS enforcement and audit environment to date
Benefits
The panel will discuss these and other important topics:
- Determining the categories of U.S. persons required to file Form 8865
- Reporting the income and expense statements and balance sheets for taxpayers with 10 percent or more interest in a foreign partnership or flow-through LLC
- Grasp key U.S. international tax reporting rules and obligations of U.S. persons with interests in foreign partnerships
- Tax basis capital reporting using current guidelines
- Avoid audit red flags and common, serious errors that the Service looks for in Form 8865 and its schedules
Faculty
Alison N. Dougherty, J.D., LL.M., CPA
Partner
Aronson
Ms. Dougherty specializes in U.S. international tax reporting, compliance, consulting, planning, and structuring as a... | Read More
Ms. Dougherty specializes in U.S. international tax reporting, compliance, consulting, planning, and structuring as a significant contributor to the firm’s international tax practice. She has extensive experience assisting clients with U.S. tax reporting and compliance for offshore assets and foreign accounts. Ms. Dougherty provides outbound U.S. international tax guidance to U.S. individuals and businesses with activities in other countries. She also provides inbound U.S. international tax guidance to nonresident individuals and businesses with activities in the U.S. Ms. Dougherty has counseled U.S. taxpayers regarding the outbound formation, capitalization, acquisition, operation, reorganization, and liquidation of foreign companies. She has significant experience with U.S. federal nonresident tax withholding, foreign partner tax withholding, and FIRPTA withholding. She works closely with nonresident individuals and businesses regarding inbound U.S. real property investment. Additionally, Ms. Dougherty has assisted U.S. taxpayers with IRS amnesty program disclosures of offshore assets and foreign accounts.
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C. Edward (Ed) Kennedy, Jr., CPA, JD
Managing Director
C Edward Kennedy Jr
Mr. Kennedy has more than 41 years of experience dealing with a variety of international tax matters, specializing in... | Read More
Mr. Kennedy has more than 41 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. Mr. Kennedy has also served as the U.S. practice leader for international social security matters for a Big 4 accounting firm. He is a frequent speaker in the areas of international tax compliance and reporting obligations U.S. information reporting requirements for foreign assets and foreign entities, U.S. tax implications of foreign pension and social security plans, and U.S. income and social tax treaty planning. Mr. Kennedy is a member of the Texas Bar and is licensed as a certified accountant in Georgia and Texas. He has a B.A. from Furman University and a J.D. from Vanderbilt University School of Law.
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