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Certain categories of US shareholders of a foreign corporation are required to file Form 5471 with the IRS. Form 5471, however, is one of the most complex forms in the Internal Revenue Code and the compliance costs for such a corporation can be very high. Such costs can be especially disproportionate for an inactive corporation […]
SECTION I. PURPOSE This revenue procedure provides a summary filing procedure for filing Form 5471 with respect to dormant foreign corporations described in section 3 below. Persons complying with this revenue procedure satisfy their Form 5471 filing obligations under sections 6038(a)(1), 6038(a)( 4), and 6046(a)(3) with respect to dormant foreign corporations and will not be […]
On November 30, 2012, the IRS announced that the underpayment and overpayment interest rates will remain the same for the calendar quarter beginning January 1, 2013. The rates will be: three (3) percent for overpayments [two (2) percent in the case of a corporation]; three (3) percent for underpayments; five (5) percent for large corporate […]
In 1988, the United States Congress enacted the Exon–Florio Amendment to authorize the executive branch’s review foreign investment within the United States. The amendment was passed into law under the Omnibus Trade and Competitiveness Act of 1988 and amended Section 721 of Defense Production Act of 1950. Generally, pursuant to this provision the President of […]
The U.S. Department of the Treasury recently announced that it is engaged with more than 50 countries and jurisdictions around the world to improve international tax compliance and implement the information reporting and withholding tax provisions commonly known as the Foreign Account Tax Compliance Act (FATCA). Enacted by Congress in 2010, these provisions target noncompliance […]