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Controlled foreign corporation (CFC) owned 100% by an
Second Opinion] Controlled foreign corporation (CFC) owned 100% by an individual... With a 962 election, GILTI is taxed at a lower rate, and a foreign tax credit can be taken on Form 1118 for tax paid… read more
Lane
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I need a CPA who has direct experience to answer this
I need a CPA who has direct experience to answer this question. A U.S. citizen living in U.S. purchased 20% of a company located in India for $200k. How will the income earned in India be taxed to the… read more
ALEX O
ALEX O
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Lane, This is on a prior question about US citizen expat
Hi Lane,This is a follow up on a prior question about US citizen expat taxes. I'd like to get more clarity on your advice that as an individual I do not need to report or file GILTY US tax and it is o… read more
Lane
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How would repatriated funds be taxed? Owners have a company
How would repatriated funds be taxed? Owners have a company in the US that receives revenue from a Foreign Subsidiary in India. And the owners also receive distributions from the Foreign Subsidiary th… read more
taxmanrog
taxmanrog
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If a CFC controlled foreign corporation paid taxes, where do
If a CFC controlled foreign corporation paid taxes, where do they go on their US shareholder tax return? How do they affect guilti ?… read more
ALEX O
ALEX O
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Second opinion] For some reason, this question showed as
Second opinion] For some reason, this question showed as answered and closed, but it is not yet.Here is the question: For the 965 inclusion amount, if the foreign corporation was not a CFC before I be… read more
taxmanrog
taxmanrog
Master's Degree
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If I have a company abroad (Brazil) and this company has a
If I have a company abroad (Brazil) and this company has a profit, let's suppose US$ 100K, but I keep US$ 50K in the company bank account (for investments) and US$ 50K I withdraw for myself as dividen… read more
ALEX O
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I am preparing a Form 1118 for an individual related to a
I am preparing a Form 1118 for an individual related to a Form 8992 (related to foreign 5471 filings). The foreign corporation is in Singapore. Where would I get the amount for "tax deemed paid" on Sc… read more
taxmanrog
taxmanrog
Master's Degree
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A US Shareholder is a 100% owner of a CFC in Europe. In 2018
A US Shareholder is a 100% owner of a CFC in Europe. In 2018 a GILTI inclusion was included on the taxpayer's Form 1040. In 2019 the shareholder received a dividend paid by the CFC on the earnings fro… read more
ALEX O
ALEX O
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I am filing 2017 Form 1040 with Section 965 filing. I have
Hello. I am filing 2017 Form 1040 with Section 965 filing. I have 10 CFC's; some have positive E&P and some have deficit E&P's. The combined E&P's are subject to the 55.7% participation deduction, as … read more
taxmanrog
taxmanrog
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Question related to GILTI Section 954()(4) “high-tax
Question related to GILTI Section 954(b)(4) “high-tax exception”, and Section 962 election.What is the order of operations and what forms should be included in the tax return of a U.S. shareholder hol… read more
Barbara
Barbara
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Fiona, I have a US corporation and am a EU citizen. I live
Hello Dr. Fiona, I have a US corporation and am a EU citizen. I live in Bermuda. My US corporation earns money with my US clients. My US corporation owns a offshore corporation in Belize. This offshor… read more
taxmanrog
taxmanrog
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I would like to know the tax implications and how the tax is
I would like to know the tax implications and how the tax is calculated for a US citizen if they own a Foreign Corporation.This could be explained by an example as well for e.g. 45% of the shares in a… read more
taxmanrog
taxmanrog
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I have set up a US corporation, Company 1. Company 1 owns a
I have set up a US corporation, Company 1. Company 1 owns a Belize corporation, Company 2. Company 2 owns a Bermuda corporation, Company 3. Will GILTI apply to Company 3 when it makes offshore profits… read more
taxmanrog
taxmanrog
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Federal Income Tax Question regarding Code Section 965 and
Federal Income Tax Question regarding Code Section 965 and 962. It involves the calculation of the tax under each section. I do have a more detailed list of information to attach to my question… read more
taxmanrog
taxmanrog
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Section 962 election A US individual owns a foreign
Section 962 election A US individual owns a foreign corporation which generates GILTI income. Can the US individual make a section 962 election (to be taxed at corporate rates) and therefore pay only … read more
Robin D.
Robin D.
Senior Tax Advisor 4
Vocational, Technical or Trade School
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GILTI tax. According to new tax bill, what is the tax rate
GILTI tax. According to new tax bill, what is the tax rate for GILTI income of a foreign corporation owned by a US individual?… read more
Robin D.
Robin D.
Senior Tax Advisor 4
Vocational, Technical or Trade School
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If I own a BVI LLC and I am a U.S citizen. do I still need
if I own a BVI LLC and I am a U.S citizen. do I still need to pay tax on the royalty income from a europen country if I elect to treat the LLC as C Corporation?… read more
Lev
Lev
44,444 satisfied customers
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