U.S. Income Tax Compliance

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US <strong>Tax</strong> <strong>Compliance</strong> Issues • When is a partnership required to file a return? • When is a foreign partner required to file a return? • If returns are required, when are they due? • Is the partnership engaged in a U.S. business? • What income is effectively connected with that business?
When is a partnership required to file a return? • General rule – every partnership is required to file a return stating its gross income, allowable deductions, and the names and addresses of its partners entitled to share in distributions of taxable income • Exceptions – Domestic partnerships – the partnership has no items of income, deductions, or credits for the year – Foreign partnerships • The partnership has no U.S. source income and • The partnership has no ECI • De minimis U.S. source income ($20,000 or less), no ECI, and U.S. partners entitled to less than 1% of items, and U.S. partners include activity on their returns
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U.S. Income Tax Compliance TTN Conf
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International Tax Forms • More Fo
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International Tax Forms • Forms f
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International Tax Forms • Forms f
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Form 926 • Exceptions - Various e
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Form 3520-A • Copies of the Forei
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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 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: Draft Form 1120-F • Other new sch
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
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U.S. Income Tax Compliance

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