Form 5472 is a required filing for any domestic LLC that is a disregarded entity and is owned by a non-U.S. person or entity. This article and video tutorial covers the filing requirements and sample Form 5472 with a proforma Form 1120.
If a partnership entity generates effectively connected income (ECI) which is allocated to nonresidents, those nonresidents are subject to withholding taxes at source. The ECI and taxes are reported on Forms 8804 and 8805.
U.S. source rental income paid to nonresidents is generally treated as FDAP income and subject to taxes on gross income. A nonresident filing Form 1040-NR can elect to treat the income as ECI and pay taxes on a net basis.
A multi member LLC is treated as a partnership for federal tax purposes. This article and video covers the basics of partnership taxation with nonresident owners and how to report on a Form 1065 for the 2020 tax year.
A multi member LLC is treated as a partnership for federal tax purposes. Not every U.S. partnership that generates profits is subject to federal income taxes. This article and video covers the basics of partnership taxation with nonresident owners.
In general, non-U.S. entities do not need to have a U.S. taxpayer identification number. In some cases, a foreign corporation may be required to obtain a U.S. tax ID if it must file an income tax return with the IRS.
The U.S. real estate market is an attractive investment opportunity for many non-U.S. individuals and businesses. This article and video discuss the rules and tax implications for non-U.S. investors in U.S. real property assets.
Content creators on YouTube and Twitch are compensated for running advertisements on their content. YouTube payouts are now characterized as royalty income rather than nonemployee compensation. This article discusses those changes.
The IRS CP282 notice is mailed to a partnership when the partnership indicated it had non-U.S. partners. In general, a U.S. partnership with effectively connected income (ECI) must include additional forms and withholding taxes. This article and video discuss the CP282 tax notice.
The U.S. limited liability company (LLC) is one of the most coveted entity types in the world. There are generally no restrictions on who can be an owner in a U.S. LLC, however, there are special reporting requirements. This article and video cover the basic reporting requirements.
