U.S. Income Tax Compliance
U.S. Income Tax Compliance
U.S. Income Tax Compliance
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From 5472<br />
• Exceptions<br />
– No reportable transactions of the type listed on the form<br />
– A US person controls the related foreign corporation and files<br />
Form 5471 with Schedule M that shows the reportable<br />
transaction<br />
– The related corporation is a FSC<br />
– The reporting corporation is a foreign corporation that does not<br />
have a PE in the US and it files Form 8833<br />
– The reporting corporation’s income is all exempt under section<br />
883<br />
– Both the reporting corporation and the related party are foreign<br />
persons and the transaction does not give rise to US source<br />
income or income that is effectively connected with a US<br />
business
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