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Controlled foreign corporation ( CFC) rules are features of an income tax system designed to limit artificial deferral of tax by using offshore low taxed entities. The rules are needed only with respect to income of an entity that is not currently taxed to the owners of the entity. Generally, certain classes of taxpayers must include in their ...
For United States income tax purposes, a business entity may elect to be treated either as a corporation or as other than a corporation. [1] This entity classification election is made by filing Internal Revenue Service Form 8832. Absent filing the form, a default classification applies. U.S. corporations of the type that can be publicly traded ...
Penalties for failure to provide foreign information. Taxpayers who are shareholders of controlled foreign corporations must file Form 5471 with respect to each such controlled foreign corporation. Penalties for failure to timely file are $10,000 to $50,000 per form, plus possible loss of foreign tax credits.
Foreign personal holding company income ( FPHCI) is defined for U.S. controlled foreign corporation rules [1] and, with modifications, for U.S. foreign tax credit rules. [2] It consists of interest, dividends, rents, royalties, gains on property producing FPHCI, and certain other items. Exceptions are provided for active rents and royalties ...
Foreign non-resident persons are taxed only on income from U.S. sources or from a U.S. business. Tax on foreign non-resident persons on non-business income is at 30% of the gross income, but reduced under many tax treaties. These brackets are the taxable income plus the standard deduction for a joint return. That deduction is the first bracket.
Foreign corporation. Foreign corporation is a term used in the United States to describe an existing corporation (or other type of corporate entity, such as a limited liability company or LLC) that conducts business in a state or jurisdiction other than where it was originally incorporated. [1] The term applies both to domestic corporations ...
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