Can someone explain the 5 categories of filers on Form 5471 in plain English?
I've been reading the Form 5471 instructions and the categories of filers section is incredibly confusing. I own shares in two different foreign companies — 8% in one and 25% in another. Both companies have other U.S. shareholders. How do I figure out which category I fall into for each company? The instructions keep referencing different code sections and the definitions seem circular.
Related Questions
One U.S. shareholder is filing Form 5471 with full schedules for the corporation. Do the other U.S. shareholders still attach anything to their own returns?
We have a foreign corporation with several U.S. owners, and our tax team is trying to use the rule that allows one person to file the main Form 5471 package on behalf of others in some cases. The prob...
My Schedule K-3 shows several foreign tax categories. Can I still combine everything onto one Form 1116 to keep the return manageable?
I am a U.S. individual investor in a foreign-focused partnership, and my Schedule K-3 includes passive category items, general category items, and a small amount that looks treaty re-sourced. I also h...
Our adviser says foreign taxes in the section 951A basket do not carry over. Is that actually different from normal Form 1116 carryovers?
I am a U.S. shareholder in a foreign operating company, and this year our international package includes foreign taxes connected to section 951A category income. I am used to hearing that unused forei...
My foreign tax changed only because of exchange rates, and the dollar difference is tiny. Can I avoid amending old U.S. returns?
I am a U.S. person in Japan and my Japanese tax liability did not really change in local currency, but when the final payment was translated into dollars the amount differed from what we accrued earli...
I sold my online business on installments. How do I handle the fact that the deal included goodwill, equipment, and inventory together?
I am from the Netherlands and sold a U.S.-based online retail brand for about $420,000. The buyer paid $90,000 at closing and the rest goes over four years. The contract bundles together the website, ...
When I move an app from personal ownership into the LLC, is the bookkeeping cutoff date as important as the platform transfer itself?
I am based in Spain and my app started under my personal accounts on Apple and Google. I now have a U.S. LLC and I am cleaning up the legal and tax side. My instinct was to focus on platform transfers...
I sold property to my brother on a note and he may flip it quickly. Can that pull the gain back into my return sooner?
I am from Italy and sold a small commercial property interest to my brother using an installment note because he could not pay all at once. The gain is significant, around $140,000. I later learned he...
I missed U.S. personal filings tied to the LLC. Can I use the streamlined procedures even though the business is an LLC?
I live in Canada and the LLC itself has its own compliance file, but my bigger issue is that I may have missed owner-level U.S. filings and FBARs tied to the way I used the structure. Someone mentione...
We already filed an amended joint return for a bigger refund. Can Form 8379 still be added after that?
I am from Australia and our original joint return understated withholding. We already filed Form 1040-X to increase the refund, and only after that did we learn my spouse had an old debt that may abso...
The offset notice says the refund went to my spouse's old state tax debt. Does Form 8379 still apply when the debt is at the state level?
I am from Ireland and my spouse had an old state income tax issue from before we were married. We filed a joint federal return this year and expected a refund of around $4,900. Treasury then issued an...
Have a similar question?
ForeignLLCTax members get expert answers with IRS citations. One CPA consultation costs $200+. Full access is $9.99/month.
Become a Member — $9.99/moDisclaimer: All content on ForeignLLCTax.com is created by a tax professional and is provided for general educational and informational purposes only. It does not constitute tax, legal, or accounting advice, and should not be relied upon as such. Every tax situation is different — for advice specific to your circumstances, please consult a licensed CPA, Enrolled Agent, or tax attorney. By using this website, purchasing a subscription, or accessing any tools or services, you acknowledge that no client-professional relationship is established between you and ForeignLLCTax.com or its operators. This website is not affiliated with the IRS.


