IRC 7701 Check-the-Box Elections for Foreign Pass-Through Entities: Structuring Hybrid Entities for Tax Planning
Lowering U.S. Income Tax on Income From Eligible Foreign Entities by Electing Tax-Advantaged Treatment
Recording of a 90-minute premium CLE/CPE video webinar with Q&A
This CLE/CPE webinar will provide tax advisers with guidance on the advantages and pitfalls of using the "check the box" election for foreign LLCs and disregarded entities. The panel will discuss the tax impact of specific elections of income from foreign disregarded entities and outline tax timing and treatment, both deferred and on repatriation.
Outline
- Purpose of "check-the-box" entity election
- Eligible entities
- Relevance determination for foreign entities
- Hybrid entities and tax planning opportunities
- Income transfer opportunities out of Subpart F
- Making retroactive entity selection or reevaluation
Benefits
The panel will discuss these and other important issues:
- How check-the-box elections facilitate the creation of "hybrid" entities
- Utilizing check-the-box elections to structure transactions 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
Faculty

Thomas M. Giordano-Lascari
Partner
Greenberg Glusker Fields Claman & Machtinger
Mr. Giordano-Lascari is a Partner in the Private Client Services Group with nearly two decades of experience... | Read More
Mr. Giordano-Lascari is a Partner in the Private Client Services Group with nearly two decades of experience in advising high-net-worth individuals and closely-held businesses with international income tax and estate planning issues.
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Patrick J. McCormick, J.D., LL.M.
Founder/Managing Partner
McCormick Tax
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.
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