Tax reporting for foreign-owned U.S. corporations
U.S. corporations with foreign ownership now need to comply with tough new IRS regulations--or face severe penalties. Shows how to meet the new compliance requirements for record maintenance and reporting to the IRS. Provides strategies for minimizing compliance and recordkeeping burdens. Following an overview of the new laws, it then offers a step-by-step analysis explaining the regulations that could preclude the penalties for noncompliance. Also included are all relevant source materials, statutes, committee reports, regulations, revenue procedures and forms.
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Recordkeeping and Reporting
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25 percent 25-percent foreign shareholder additional penalty agency agreement amounts apply Assistant Commissioner International authorization of agent compliance comply determined District Director enforcement example failure to maintain file Form 5472 final regulations foreign corporation foreign person foreign related party foreign sales corporation foreign-owned corporations Formal Document Request gross revenue high profit test identifiable assets income tax income tax return industry segment test intercompany Internal Revenue Code Internal Revenue Service jurisdiction loss statements maintain records monetary penalty noncompliance penalty procedure products or services profit and loss quash reasonable cause record maintenance requirements related party group related party transactions relevant reportable transactions reporting corporation retroactive return on assets safe harbor provisions Secretary section 482 service of process significant industry segment specific summons tax treaty taxpayer tion Toyota Motor Corporation Toyota Motor Sales trade or business Treas U.S. corporation U.S. tax U.S.-connected products United Vetco