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Kings New York online Form 5471 (Schedule J): What You Should Know
This form includes the name and address of those U.S. persons with possession of ownership of corporate interests, their domestic corporate tax residence (Form 5471 Schedule J) and the taxpayer's estimated tax liability for the year on those foreign profits in the year. [The IRS] would issue Form 5471 to foreign entities that were created or acquired after May 1, 1982, at which time the law entered into effect which allowed foreign corporations to own and operate U.S. corporations on paper. While U.S. companies could now sell their shares of foreign companies to foreign persons or foreign entities, the ownership of those shares was not transferable or taxable. While not a U.S. person, an entity that purchased shares in a U.S. company would also report the sale on Form 6166 (or Form 5328), for domestic shareholders, and on Form 5472, for foreign shareholders. [On the other hand, non-U.S. persons may sell their shares at a later date to another non-U.S. person at taxed in another country or state of the U.S., who would no longer be a U.S. person.] In the case of a U.S. person who owns stock in a foreign corporation and is also taxed to the foreign jurisdiction where the corporation is located, if the transaction has been effected at a time or at a place that has no reasonable proximity to ownership of a U.S. corporation, Form 5471 is a Schedule I report and may be required. [Some people are confused by the language in the title of this article. “Non-U.S. person” in this case means a “person not a U.S. citizen or U.S. resident” (unless otherwise noted in the article), and this “person not a U.S. citizen or U.S. resident” means someone NOT eligible to use the “foreign tax credit” (the foreign tax return) that can be claimed by a U.S. person as described in IRS Publication 334. [A U.S. person, by the way, may claim the foreign tax credit in any year that's appropriate for the tax return year for which the credit is claimed if you qualify.
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