Have a Tax Question? Ask a Tax Expert
An LLC that was a partnership and loses its last partner, so that it has only a single owner becomes a disregarded entity. Treas. Reg.(###) ###-####3(f)(2). The LLC owner would report its income on the foreign corporation's IRS Form 1120-F.
At this time the foreign corporation is not required to file form 5472. However, the IRS has issued proposed regulations (IRB 2016-21), which when published as final, will require filing of the form.
I hope I've answered your question. Please let me know if you require further clarification. And, please provide a positive feedback rating for my answer (click 3, 4 or 5 stars) -- otherwise, I receive nothing for my efforts in your behalf.
Thanks again for using Justanswer!
No they cannot file as a partnership, and yes, they will be late. See 1120-F Instructions -- When to File (page 4).
No, the foreign corporation that is receiving the income would have to file the 1120-F.
I see that you have reviewed my answer, but that you have not provided a rating. Do you need any further clarification concerning my answer, or is everything satisfactory?
If you need further clarification, concerning this matter, please feel free to ask. If not, I would greatly appreciate a positive feedback rating for my answer (click 3, 4 or 5 stars) – otherwise, I receive nothing for my efforts in your behalf.Thanks again for using Justanswer!
I believe that you are looking for the proverbial "pot-o-gold at the end of the rainbow."
No law exists to support your desired outcome. I wish it were otherwise, because there is no benefit to my delivering bad news to you.