admin

GILTI Tax

Similar to a subpart F inclusion, “U.S. Shareholders” of CFCs include GILTI in income on an annual basis. U.S. corporations may be entitled under section 250 to a deduction of …

GILTI Tax Read More »

Form 8621 (PFIC)

Required when there is distribution of income from a passive foreign investment company (PFICs) in which a U.S. person is a shareholder or a disposition of the shares of a …

Form 8621 (PFIC) Read More »

Form 3520

Annual Return to Report Transactions With Foreign Trusts and Receipt of Certain Foreign Gifts Usually amounts of $100,000 or more are required to be reported in a calendar year.

Form 5471 (CFCs)

U.S. citizens and U.S. residents who are officers, directors, or shareholders in certain foreign corporations are responsible for IRS Form 5471 filing. Under the TCJA, rules requiring the inclusion of …

Form 5471 (CFCs) Read More »