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Form 8865: Handling Complex Challenges When Reporting Foreign Partnership Income

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.

Runtime: 107 minutes
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Why Lorman?

Over 32 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 32 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 Webinar

This course was last revised on March 29, 2019.

Call 1-866-352-9540 for further credit information.

  • Enrolled Agents 2.0
     
  • This program qualifies for 2.0 hours of Continuing Education Credit for enrolled agents under Treasury Department Circular #230 Section 10.6(g).
     

This program does NOT qualify, nor meet the National Standard for NASBA accreditation.

Audio & Reference Manual

This program does NOT qualify, nor meet the National Standard for NASBA accreditation.

MP3 Download

This program does NOT qualify, nor meet the National Standard for NASBA accreditation.

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More Program Information

Why Lorman?

Over 32 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

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

Michael Lehmann

Dechert LLP

  • Partner in the New York and Philadelphia offices of Dechert LLP, has practiced tax law and nonprofit 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
  • Member of New York and Pennsylvania Bars; Tax Court Bar; NY Bar Association; American Bar Association
  • LL.M. degree in Taxation, New York University; J.D. degree, Columbia University; A.B. degree, Brown University
  • Can be contacted at [email protected], 212-698-3803 or 215-994-3803
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Product ID: 403560
Published 2019
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