Classifying Foreign Entity Structures for U.S. Taxation: U.S. Reporting Requirements

This webinar will identify the most frequent foreign entity structures encountered by U.S. international tax practitioners and their U.S. reporting requirements. Our panel of astute foreign tax professionals will divulge how these structures correspond with U.S. entity reporting structures, how they are reported and taxed in the U.S., and when a check-the-box election could be relative and beneficial.

There are at least eight types of entities in the U.K.: public limited companies, private company limited by shares, and Royal Charters are included among these. Structure choices in Switzerland include Aktiengesellschaft (AG), public limited company (SG) corporations, and joint stock companies. The foreign entity types do not always correlate with U.S. entity classifications, including corporations, partnerships, LLCs, and sole proprietorships.

There are default U.S. classifications for entities depending on the number of owners and whether owners have limited liability. Some foreign entities are eligible to elect their status on Form 8832 and choose whether to be treated as a partnership or corporation. How an entity is treated in the U.S. is a critical determination. This determines the entity's reporting obligations, how distributions are taxed, and its withholding obligations. Tax professionals working with multinational taxpayers need to be able to readily identify common overseas entity structures and how these could be taxed in the United States.

Listen as our panel of international tax attorneys details common foreign country structures and their reporting and tax obligations in the United States.