controlled foreign corporation Archives

Feature Article

Foreign Corporations, Form 5471, and the Perils of Offshore Noncompliance

Form 5471 is required to be filed by United States (U.S.) persons—citizens, resident aliens, domestic partnerships, and corporations, and certain estates and trusts—who are officers, directors, or 10... Manasa Nadig, EA

Spring 2026, Feature Article, FBAR, Schedule C, GILTI, Schedule E, Form 8938, Form 926, Form 5471, Form 3520, Form 3520-A, fair market value, Schedule A, CDP, §965, controlled foreign corporation, CFC, Schedule I, FMV, Schedule F, Schedule B, Farhy v. Commissioner, §6038(c), foreign corporation, offshore noncompliance, §6679, §6046, §6038B(c), §318, Treas. Reg. §1.6046-1(i), §958(a), §958(b), Schedule G, §6013, Schedule H, Schedule M, Schedule O, Schedule P, Schedule Q, Schedule R, §6677, Raj J. Mukhi

Feature Article

Unmasking the Myths: Who Can Truly Be a Shareholder in an S Corporation?

Revisiting the Basics of the S Corporation: Nonresidents as Shareholders Small business corporations are more popular than ever. You hear about them on social media, and among the tax community. Indeed, sm... Fernando Juarez, EA, and Edgar Gonzalez, EA

Spring 2025, Feature Article, TCJA, Tax Cuts and Jobs Act, s corporation, c corporation, GILTI, nonresident alien, ITIN, small business, partnerships, beneficiary, controlled foreign corporation, CFC, SSN, §1362(d)(2), shareholders, double taxation, foreign bank account, green card test, substantial presence test, Treas. Reg. 1.1361-1(g)(1)(i), §7701(b)(1)(B), §7701, Office of the Chief Administrative Hearing Officer, OCAHO, Immigration Reform and Control Act of 1986, Immigration Act of 1990, electing small business trust, ESBT, tax treaty, global intangible low-taxed income, Form 8833, Treas. Reg. §301.7701(b)-7, INTL-121-90, §1361(a)(1), §1361(b)(2)(C), §1362(a), Treas. Reg. §301.7701(b)-7(a)(4), §957, §552

Supreme Court

U.S. Supreme Court to Consider Constitutionality of Repatriation Tax: Moore v. United States

The United States Supreme Court will consider the constitutionality of Internal Revenue Code (IRC) §965, which mandated the repatriation tax on previously untaxed income from controlled foreign corporations (CFCs). Rita M. Ryan, JD

Spring 2024, Supreme Court, TCJA, Tax Cuts and Jobs Act, §965, §965(g), Moore v. United States, 16th Amendment, controlled foreign corporation, CFC