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Information provided on this site is for general guidance only and
is often simplified. Actual IRS procedures are complex, and taxpayers
should obtain professional assistance or use IRS sources for complete
information.
Foreign
Corporations The corporate
forms businesses may use to operate outside the
US and their tax characteristics.
Controlled
Foreign Corporation A
US person who is a shareholder of a CFC is potentially
liable for US tax and required to keep records.
DISC
A corporation must elect IC-DISC
status by filing Form 4876-A.
Partnerships
The payments of withholding tax required to be
made during a partnership's tax year are to be
reported on Form 8813 and paid over to the IRS
(in US currency). A partnership must generally
pay to IRS a portion of its estimated annual section
1446 payment for each foreign partner by the 15th
day of the fourth, sixth, ninth, twelfth months
of the partnership's tax year for US income tax
purposes. Any additional amounts determined to
be due are generally to be paid with the filing
of Form 8804.
Tax rate.
The
withholding tax rate on a partner's share of effectively
connected income at the time of writing is 35%
for a partner taxed as a corporation, and 39.6%
for all other partners, such as individuals, partnerships,
and estates.
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Our 16 constantly
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of 'offshore' and international tax-planning in depth, including
banking secrecy, the EU's savings tax directive, offshore
funds, e-commerce, offshore gaming and transfer pricing. Reports
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advice before committing themselves to involvement in offshore jurisdictions,
offshore trusts or offshore investments. All materials on this site copyright
The Lowtax Network 1999 - 2007. Contact
us for further information.
