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Form 5471 Anchorage Alaska: What You Should Know
Certain Foreign Corporations) or report an active loss on their Schedule K-1 or Schedule C (Information Return of U.S. Persons With Respect to Certain Foreign Tax Matters). However, a domestic partnership electing to withhold under the alternative minimum tax might need to change the type and amount of deductions of active losses from the partnership's income and report the loss to the Tax Court, rather than filing Form 5471 (Information Return of U.S. Persons With Respect to Certain Foreign Corporations). A foreign entity's failure to make a U.S. shareholder election that the IRS had proposed, which was not accepted, would still report to the IRS the partnership's domestic income to the extent it is attributable to such income. In addition, under the rules in subsection (f) of section 897(e)(1)(R) of the Internal Revenue Code, foreign entities that fail to take such a U.S. shareholder election may have to pay U.S. tax on their worldwide foreign income. Other Changes From December The final Sec. 958 regulations will continue to have no impact on: the obligations of a non-U.S. person that elects to treat its passive foreign investment company income and its passive foreign investment company losses as its nondeductible business income for U.S. federal income tax purposes; and the obligation to apply the shareholder election to a partnership that does not, on the partnership's return of income, disclose its passive foreign investment company income or pass-through income, except to the extent such income or pass-through income is attributable to passive foreign investment company income and the partnership's passive foreign investment company losses. On the other hand, the final regulations will have a significant impact on a foreign person that provides a foreign trust with a pass-through or other type of foreign source income. A foreign person that provides a foreign trust with a Pass-through, passive foreign investment company, or foreign trust income, as the case may be, and to the extent such income is attributable to passive foreign investment company sources other than passive foreign investment company income, may have a deferred tax liability under section 871, and be required to include such deferred tax liability in income under sections 77 or 707 of the Code, and the final regulations impose reporting requirements to the IRS that will require such foreign person to report their passive foreign investment company source income or pass-through income when required. The regulations also provide that a foreign person's non-U.S.
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