Recent content by Wanderien

Yea, I was reading https://www.irs.gov/forms-pubs/about-form-8832 Just had never encountered that form, since it's a 'domestic entity', not a European company. And that's where my confusion stemmed from, the definitions of domestic and foreign are about the entities, not the 25% or 100% owners...

Ah, perhaps I panicked a bit too fast again… And the default rules are talking about the entity, and not its owner. Foreign-Owned Domestic LLC LLC is formed in Wyoming (U.S.) → domestic entity under IRS rules (§301.7701-5(a)). Non-U.S. owner → foreign ownership, but the entity itself is...

This went over my head, to be honest, and thought 8833 you mentioned doesn't apply to me. But I just encountered form 8832, which I had never heard of. According to the Foreign default rule without making a specific election. Foreign default rule. Unless an election is made on Form 8832, a...

OK, cheers for that extra coloring! He said the following: "I think your risk is low, since your income is exempt by treaty. The IRS would have little motivation to go after you. However, as you say, the filing requirement is very factual." Implying that I would need to file, and would not be...

Thanks for the share of that CFR. The one you shared doesn't have much written, but the next ones do, cheers! Could you tell us why you would read that over the code? I assume it's for the clearer language, and examples given on 26 CFR § 1.864-3, 1.864-4, and so on?

Thanks for sharing, that's interesting. I have hired GW Carter for the first year I filed my f5472. When I did it the next year by myself, I noticed that their team hadn't asked me the right questions to fill out the form correctly. So that was money down the drain, for sure. His response...

Not necessarily.

I think you're the one understanding it correctly, and indeed an LLC does not pay out dividends. The IRS disregards a single-member LLC for tax purposes, so the profits from the LLC get taxed straight into the income tax in the country where the owner of the LLC is a resident. As you also...

From what I understand reading the case law and onine resources... Most likely, yes.