I am an unrelated minority U.S. shareholder in a foreign-controlled CFC and cannot get full tax books. Does the IRS let me use alternative information?
I own a minority stake in a foreign corporation that may be a foreign-controlled CFC, but I do not have the power to demand full tax accounting packages from the controlling foreign owners. That makes the Form 5471 and GILTI work feel almost impossible, because the detailed tax information the return seems to want is not actually available to me.
I heard the IRS created a safe harbor or alternative-information relief for some minority U.S. shareholders in this exact situation. If that is true, I need to know whether it is a real filing path or just soft comfort language with no practical return consequence.
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