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Rochester New York Form 5471 (Schedule J): What You Should Know
See instructions to Schedule O(8)(a)(2). E&P of foreign business (F&P) income Exceptions for foreign financial accounts NEW YORK, NY 10036 – 2519 Exclude foreign financial accounts of: Business: Domestic foreign exchange accounts (foreign currency held in an account that was in the U.S. at the end of the tax year that the trust is treated as operating; see section 993(c)). Management of a foreign trust (§ 988, et seq. ) if it qualifies to be treated as a separate entity for U.S. federal income tax reporting purposes (§ 991, et seq. ). Section 990 (§ 995) business property (§ 991(l)) Foreign financial account transactions (§ 998 (i). ) Foreign personal holding company (§ 982) transactions. Taxable dividends (§ 988 (a)(7)) E&P, F&P, and gross income from foreign operations of a controlled foreign corporation Reporting of income and deductions from foreign operations of controlled foreign corporations. E&P of passive foreign investment companies (F&P) Exempt foreign financial accounts of a controlled foreign corporation (§ 988 (c)), § 991, and § 995 (f) of the Internal Revenue Code. Foreign personal holding company by a related party. Management transaction of a controlled foreign corporation (§ 991 (h) of the Internal Revenue Code. Management transaction of a foreign branch (§ 991 (i) of the Internal Revenue Code. U.S. resident alien's income (§ 907) Determination of withholding for tax year 2025 (c)(2) transactions to taxpayers without a domestic partnership Report of foreign taxes by a U.S.-person who is in active service with a controlled foreign corporation (see Exceptions and special rules below.) Section 994 (§ 995) interest paid in a holding company by a related person. Determination of withholding for tax year 2025 (c)(2) transactions to taxpayers without a domestic partnership Report of foreign taxes by a U.S. resident alien who has a domestic partner. Section 994 (i) foreign taxation on transfer of ownership. Form 1120 from the transferor to the transferee Report of foreign taxes paid in a holding company by a related person by using Form 1120G in lieu of Form 1120.
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