The Curious Case Of The Accidental American Taxpayer
The following article was published on Law360 on September 26, 2018. I’m honored to be a contributor to this fine legal publication. Click here to read the article.
A Quick Primer on Form 5471 and Some Hidden Pitfalls to Avoid
Form 5471 is triggered in situations where a “U.S. Person” owns an interest in a “foreign” (non-U.S.) corporation. The specific reporting requirements for Form 5471 are found in Internal Revenue Code Sections 6038 and 6046. Broadly speaking, the purpose of Form 5471 is to identify “U.S. Persons” who: own at least 10% of a “non-U.S.” […]