U.S. Income Tax Compliance

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Form 8865 • Who must file? – Category 3 - A U.S. person who contributed property to a foreign partnership in exchange for an interest in the partnership if that person either • (1) owned directly or constructively at least a 10% interest in the foreign partnership immediately after the contribution or • (2) the value of the property contributed (when added to the value of any other property contributed to the partnership by such person, or any related person, during the 12-month period ending on the date of transfer) exceeds $100,000. • For this purpose, if a domestic partnership that contributes property to a foreign partnership, the domestic partnership’s partners are considered to have transferred a proportionate share of in the property contributed to the partnership. However, if the domestic partnership files Form 8865 and properly reports all the required information with respect to the contribution, its partners will not be required to report the transfer.
Form 8865 • Who must file? – Category 3 also includes a U.S. person who previously transferred appreciated property to the partnership and the foreign partnership disposed of such property while the U.S. person remained a direct or indirect partner – Category 4 - A U.S. person that had a reportable event during the tax year
Page 1 and 2: U.S. Income Tax Compliance TTN Conf
Page 3 and 4: International Tax Forms • More Fo
Page 5 and 6: International Tax Forms • Forms f
Page 7 and 8: International Tax Forms • Forms f
Page 9 and 10: Form 926 • Exceptions - Various e
Page 11 and 12: Form 3520-A • Copies of the Forei
Page 13 and 14: Form 3520 • Who must file? - A re
Page 15 and 16: Form 3520 • Where and when to fil
Page 17 and 18: Form 5471 • Who must file? - Cate
Page 19 and 20: Form 5471 • A U.S. person has con
Page 21 and 22: Form 5471 • Penalties - A $10,000
Page 23 and 24: Form 5471 • Penalties - Any perso
Page 25 and 26: Form 8858 • A foreign disregarded
Page 27: Form 8865 • Who must file? - Cate
Page 31 and 32: Form 8865 • When and where to fil
Page 33 and 34: Form 8865 • Penalties - Category
Page 35 and 36: Form 8865 • Penalties - Category
Page 37 and 38: Form TDF 90-22.1 • A financial ac
Page 39 and 40: Form TDF 90-22.1 • Signature Auth
Page 41 and 42: From 5472 • Who must file? - Any
Page 43 and 44: From 5472 • Exceptions - No repor
Page 45 and 46: Form 5472 • When and where to fil
Page 47 and 48: Form W-7 • Who must file? - Any i
Page 49 and 50: Form W-7 • When and where to file
Page 51 and 52: Form 8832 • When to file - An ele
Page 53 and 54: Forms 8804, 8805, and 8813 • Who
Page 55 and 56: Forms 8804, 8805, and 8813 • Wher
Page 57 and 58: Forms 8288, 8288-A, and 8288-B •
Page 63 and 64: Other Forms • Where to file Form
Page 65 and 66: Draft Form 1120-F • Other new sch
Page 67 and 68: When is a partnership required to f
Page 69 and 70: When is a foreign partner required
Page 71 and 72: Examples • Every domestic partner
Page 73 and 74: Examples • Answer depends on the
Page 75 and 76: What are the due dates for the retu
Page 77: What are the due dates for the retu

U.S. Income Tax Compliance

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