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International tax · IRC §§ 6038, 6038B, 6046A
Partnership firms, LLPs and some LLCs formed outside the US are often treated as partnerships for US tax purposes. US partners may need to file Form 8865 and report their share of income each year.
Serving United States, Virginia, Washington, DC, Maryland.
What we handle
A US person who controls a foreign partnership, owns 10% or more of one controlled by US persons, contributes property to one, or acquires or disposes of a significant interest may have to file Form 8865. Indian partnership firms and LLPs, and many foreign joint ventures, fall into these rules.
Partners also report their share of the partnership's income on their own return, with foreign tax credits for tax paid abroad. Entity classification matters: some foreign entities can elect to be treated as partnerships, corporations or disregarded entities, which changes which form applies.
Speak with an advisorWhere we help
$10,000 per form per year for failing to file, with continuation penalties after notice.
A penalty of 10% of the value of property transferred, up to $100,000 absent intentional disregard.
Treas. Reg. § 301.7701-3 decides how a foreign entity is classified for US tax.
The statute of limitations stays open until the form is filed.
Our approach
A senior advisor reviews your facts and documents.
Scope, fees and timeline in an engagement letter.
Returns, elections and forms prepared and reviewed.
IRS contact and planning all year.
Questions
If your question isn't here, call (703) 880-8412 and you'll reach a person.
Usually, unless an election was made otherwise. US partners may need Form 8865 and must report their share of income.
Possibly. Reporting can be triggered by contributions, acquisitions or dispositions even for small interests.
Generally yes, foreign income taxes attributable to you can be claimed as foreign tax credits, subject to limits.
We review the years and use delinquent information return or Streamlined procedures to reduce penalty risk.
Latest updates
FinCEN issued a final rule revising BOI reporting. Business owners should confirm whether their entities still have a filing obligation.
Source: Federal Register
The IRS took down the page that described penalty relief for late FBARs when all income had been reported. Get advice on reasonable cause or the Streamlined procedures before filing late FBARs.
Source: EY Tax News
Related
Streamlined Domestic Offshore Procedures (SDOP), Streamlined Foreign Offshore Procedures, late FBAR and international information return filings, and voluntary disclosure support for foreign accounts and assets.
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