Control Rules
Any U.S. Person who controls a foreign corporation or foreign partnership during the tax year must file a Form 5471 (for a corporation) or Form 8865 (for a partnership). (IRC §6038.) These forms must be filed with the U.S. Person’s timely filed federal tax return (including extensions).
For foreign [...]
Source: http://feeds.feedburner.com/~r/IRSTaxAuditNews/~3/311346082/
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