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Printable Form 5471 Simi Valley California: What You Should Know
IRS‑00221 The form can be filed electronically using NETTLE. Do not prepare any paper forms, except when absolutely necessary. Income Tax Treatment of Passive Foreign Investment Companies In general, it's not the company that pays the tax; it's the passive foreign investment company (PFC). The tax applies to the entire interest, dividend and other income and/or gain that flows through the company, regardless of whether the company actually pays taxes in the United States. A PFC is treated as an S corporation, which is taxed as an income-producing corporation, that the shareholders and non-U.S. shareholders together own 60% or more of. The shareholder is taxed like a domestic non-U.S. shareholder. Interest and dividends income of an S corporation is taxed by the U.S. shareholder. Interest and dividend income of Pics are not taxed by the U.S. shareholder, but are taxed by the foreign non-U.S. shareholder separately for U.S. tax purposes. In addition, the foreign non-U.S. shareholder must allocate the earnings to its U.S. shareholders in the same manner as would be a U.S. shareholder who allocates the same earnings from a U.S. partnership. Because Pics can't use cash and pay U.S. taxes on their income as U.S. shareholders, it's useful to define Pics as a type of “passive fund” that can take in a capital loss carry forward, as described above. Non-U.S. shareholders can choose to have their income earned abroad, but must pay U.S. tax on the income earned. Foreign shareholders who choose not to retain any amount of foreign earnings from their Pics, and who pay U.S. tax on their foreign earned income, are generally considered non-U.S. shareholders for purposes of determining the tax treatment of their Pics. The tax code has changed in several ways to make it easier for U.S. persons to hold and have assets outside the United States. Since 2012, U.S. persons no longer pay U.S. tax on a foreign non-U.S. corporation's foreign-source earnings if the foreign non-U.S. shareholder is a U. is of the U.S. (or is a U.S. person themselves).
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