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

Identifying Canada, Switzerland, the United Kingdom, and Other Countries' Common Entity Types

Note: CLE credit is not offered on this program

A live 110-minute CPE webinar with interactive Q&A

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Monday, November 25, 2024 (in 4 days)

1:00pm-2:50pm EST, 10:00am-11:50am PST

(Alert: Event date has changed from 11/26/2024!)

or call 1-800-926-7926
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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.

Description

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.

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Outline

  1. Identifying and reporting foreign entities in the U.S.
  2. Why it matters
    1. Dividends and distributions
    2. Withholding
    3. Other considerations
  3. U.S. default classification rules
  4. Check-the-box elections
  5. U.S. reporting requirements
  6. Other country entity types
    1. United Kingdom
    2. Canada
    3. Germany
    4. Australia and New Zealand

Benefits

The panel will cover these and other critical issues:

  • How common Canadian entities are reported and taxed in the U.S.
  • How a foreign entity's U.S. classification affects the taxation of distributions to its owners
  • When a foreign entity is eligible for a check-the-box election
  • How limited liability of owners affects U.S. tax status

Faculty

Kennedy-C. Edward
C. Edward (Ed) Kennedy, Jr., CPA, JD
Managing Director
C Edward Kennedy Jr

Mr. Kennedy has more than 42 years of experience dealing with a variety of international tax matters, specializing...  |  Read More

McCormick, Patrick
Patrick J. McCormick, J.D., LL.M.
Partner
Rimon Law

Mr. McCormick specializes in the areas of international taxation and multinational trusts and estates. He has...  |  Read More

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