The Resource IRS proposes Form 5472 filing duty for foreign-owned disregarded entities

IRS proposes Form 5472 filing duty for foreign-owned disregarded entities

Label
IRS proposes Form 5472 filing duty for foreign-owned disregarded entities
Title
IRS proposes Form 5472 filing duty for foreign-owned disregarded entities
Creator
Subject
Language
eng
Summary
The U.S. government, fed up with international tax evasion, has taken significant steps in recent years to curb the problem. Among the most notorious of these steps was the enactment of the Foreign Account Tax Compliance Act (FATCA), which effectively forces foreign financial institutions to provide the IRS with valuable data about U.S. clients. International organizations have pointed out a flaw with these efforts: while occupied pressuring others to surrender client data, the U.S. government supposedly has failed to keep its own house in order. The major criticism is that, as a result of gaps in U.S. tax law, foreigners can easily hide money in the United States by utilizing a domestic, single-member, limited liability company, treated as a disregarded entity (DRE) for federal tax purposes. In an effort to halt this practice, the IRS issued proposed regulations in May 2016 (Proposed Regulations) that would obligate foreign-owned, single-member, domestic DREs to file annual Forms 5472 (Information Return of a 25-percent-Foreign-Owned U.S. Corporation or a Foreign Corporation Engaged in a U.S. Trade or Business) with the IRS. This article explores important aspects and consequences of the Proposed Regulations
Citation source
In: International tax journal. - Chicago. - Vol. 42 (2016), no. 4 (July-August) ; p. 17-32
http://library.link/vocab/creatorName
Sheppard, H.E
Geographic coverage
North America
Language note
English
http://library.link/vocab/subjectName
  • FATCA
  • banking
  • limited liability company
  • disregarded entity
  • penalties
Label
IRS proposes Form 5472 filing duty for foreign-owned disregarded entities
Instantiates
Publication
Label
IRS proposes Form 5472 filing duty for foreign-owned disregarded entities
Publication

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