Mar 23, 20213 minLate Relief Granted for Late Filing of Entity Selection Form 8832 (Ruling 202111010)Form 8832, ‘Entity Classification Election’ Eligible foreign and domestic entities use the Form 8832 to elect how it will be classified...
Mar 23, 20211 minThe Impact of TCJA’s Repeal of the §958(b)(4) ‘Downward Attribution Rule’The TCJA repealed §958(b)(4) which stated that the ‘downward attribution’ rule of 318(a)(3) was not to be applied so as to consider a US...
Mar 11, 20213 minNew Categories of Filers on the 2020 Form 5471US persons who fall within one of five categories of filers must file a Form 5471, 'Information Return of U.S. Persons With Respect to...