Be aware of potential filing and reporting obligations and be equipped to comply with them.
Congress and the Internal Revenue Service continue to increase filing and information reporting requirements on U.S. persons who own interests in foreign entities, transact business with foreign entities and conduct business abroad. The categories of U.S. persons who are obliged to make these different filings, and the information required by these filings, continuously grows in sweep and complexity. The penalties that can be imposed on U.S. persons who fail to comply with these requirements are among the most severe in the Internal Revenue Code. Added to this is an ever-increasing focus by the Internal Revenue Service on international tax compliance. Finally, the use of the partnership/pass-through form of entity has exploded over recent years. This combination of more reporting, more complexity, more compliance and greater potential penalties is a potentially toxic brew for the unprepared taxpayer and tax advisor. This topic will help persons who deal with cross-border pass-through entities be aware of potential filing and reporting obligations and be equipped to comply with them.
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Why Lorman?
Over 37 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.
Agenda
Foreign Partnership Basics
- What Is a "Partnership"?
- When Is a Partnership a "Foreign" Partnership?
- What About Hybrid Entities?
Key Definitions and Ownership Rules
- What Is a "Us" Person?
- How Do the Constructive Ownership Rules Work?
Who Has to File Form 8865
- Control Persons - the Category 1 Filer
- U.S. Controlled Partnerships - the Category 2 Filer
- Property Contributors - the Category 3 Filer
- Acquisitions/Dispositions/Changes of 10% Interests - the Category 4 Filer
- Overlapping Categories
- Special Situations
Filing Form 8865
- Differences Between Form 8865 and Other Key International Returns Such as 8939 and 5471
- Key Elements of the Schedules for Form 8854
- How and Where to File Form 8865
Penalties Associated With Form 8865
- Failure to Timely Submit Information
- Failure to Properly Report Property Contributions
- Failure to Properly Report Changes of Interests
- Penalty Abatement Strategies
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Why Lorman?
Over 37 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.
Credits
OnDemand Course
This course was last revised on March 29, 2019.
Call 1-866-352-9540 for further credit information.
This program does NOT qualify, nor meet the National Standard for NASBA accreditation.
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Why Lorman?
Over 37 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.
Faculty
Kimberly Goldman
Dechert LLP
- Associate in the New York office of Dechert LLP, specializing in tax law
- Membership information: New York Bar; American Bar Association
- J.D. degree, University of Michigan Law; B.A. degree, University of Wisconsin-Madison
- Can be contacted at 212-698-3520 or [email protected]
Michael Lehmann
Dechert LLP
- Partner in the New York and Philadelphia offices of Dechert LLP, has practiced tax law and non-profit organizations law for over 32 years
- Practice emphasizes multiple aspects of federal tax law, including extensive representation of private foundations and other nonprofit organizations ranging from small community based nonprofits to global foundations managing billions of dollars of assets
- Conducts regular seminars and workshops on numerous tax and state law topics applicable to nonprofit organizations
- Education: AB, Brown University; JD, Columbia University; LL.M. (Taxation), New York University
- Membership information: New York and Pennsylvania Bars; Tax Court Bar; NY Bar Association; American Bar Association
- Can be contacted at [email protected] or 212-698-3803 or 215-994-3803
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Why Lorman?
Over 37 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.
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