Form 8275 or Form 8275-R — which one do I file to disclose a tax position on my foreign-owned LLC return?
My CPA wants to take a position on my U.S. LLC's pro forma 1120 that he says goes against a Treasury regulation. He mentioned filing either Form 8275 or Form 8275-R but I don't really understand which one applies. What's the difference, and what happens if I file the wrong one or skip the disclosure entirely?
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