Form 8858 Reporting of U.S. Owned Foreign Disregarded Entities: Ownership and Correct Filing Status
Information Return Requirements for Check-the-Box Structures Including Indirect and Constructive Ownership
Note: CLE credit is not offered on this program
Recording of a 110-minute CPE webinar with Q&A
This course will guide tax advisers to the U.S. reporting requirements for ownership of foreign disregarded entities (FDEs) on IRS Form 8858. The panel will offer section-by-section detail on completing Form 8858, discuss the interrelation between Form 8858 and other required international information reporting, and review IRS enforcement practices and actions through their filing checks/matching examination process.
Outline
- Classification of FDEs
- Definition for U.S. tax purposes
- Examples of foreign structures
- Check-the-box elections and impact on Form 8858 filing requirements
- Types of ownership
- Direct
- Indirect
- Constructive
- What's new: latest IRS form revisions
- Critical sections of Form 8858 which lead to IRS scrutiny
- Intersection with Forms 5471 and Form 8865
- Penalties for noncompliance
Benefits
The panel will discuss these and other vital questions:
- Identifying Form 8858 reporting obligations from Form 5471 and Form 8865 filings
- Recognizing the types of ownership of FDEs and how indirect or constructive ownership impacts which sections of Form 8858 must be completed
- Penalties involved in Form 8858 noncompliance
- Completing the individual sections of Form 8858
Faculty
Alison N. Dougherty, J.D., LL.M., CPA
Partner
Aronson
Ms. Dougherty specializes in U.S. international tax reporting, compliance, consulting, planning, and structuring as a... | Read More
Ms. Dougherty specializes in U.S. international tax reporting, compliance, consulting, planning, and structuring as a significant contributor to the firm’s international tax practice. She has extensive experience assisting clients with U.S. tax reporting and compliance for offshore assets and foreign accounts. Ms. Dougherty provides outbound U.S. international tax guidance to U.S. individuals and businesses with activities in other countries. She also provides inbound U.S. international tax guidance to nonresident individuals and businesses with activities in the U.S. Ms. Dougherty has counseled U.S. taxpayers regarding the outbound formation, capitalization, acquisition, operation, reorganization, and liquidation of foreign companies. She has significant experience with U.S. federal nonresident tax withholding, foreign partner tax withholding, and FIRPTA withholding. She works closely with nonresident individuals and businesses regarding inbound U.S. real property investment. Additionally, Ms. Dougherty has assisted U.S. taxpayers with IRS amnesty program disclosures of offshore assets and foreign accounts.
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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
Mr. Kennedy has more than 42 years of experience dealing with a variety of international tax matters, specializing in tax consulting services to a wide variety of clients ranging from closely held companies to multi-national businesses. His expertise includes domestic and foreign income and social security tax planning, tax compliance for individuals and corporations, tax treatment of incentive compensation plans, international assignment program administration, and international assignment policy design. Mr. Kennedy has also served as the U.S. practice leader for international social security matters for a Big 4 accounting firm. He is a frequent speaker in the areas of international tax compliance and reporting obligations U.S. information reporting requirements for foreign assets and foreign entities, U.S. tax implications of foreign pension and social security plans, and U.S. income and social tax treaty planning. Mr. Kennedy is a member of the Texas Bar and is licensed as a certified accountant in Georgia and Texas. He has a B.A. from Furman University and a J.D. from Vanderbilt University School of Law.
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