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As a boutique international tax advisory firm, we’re finding international tax issues arising for individuals and companies of all sizes. Many of them never thought they would have any cross-border activities. We thought it might be helpful to do a series of discussions on International Tax for the Non-Specialist. They are overviews designed to assist practitioners and taxpayers to identify issues. The overviews dive into some level of detail, but we envision separate sessions to more fully explain various technicalities.

There is no need to view the presentations in any particular order. This discussion is #6 in the series, following: #1 on tax residency and foreign financial account disclosures [FBAR / FinCen 114 / Form 8938]; #2 on earning foreign income and an employee being transferred to a foreign affiliate [including the foreign earned income and housing exclusions]; #3 on the anti-deferral rules of Subpart F and identifying a controlled foreign corporation (CFC); #4 on US income taxation of Nonresidents; and #5 on the anti-deferral rule of Internal Revenue Code §956, Investment of Earnings in US Property.

The presentation is a practical overview of the entity classification rules. It reviews entity classification types, a brief history of the pre-check the box election guidance and how/why one might make an election. The primary focus is on foreign entities.

This includes, but is not limited to: 1. Pre-check the box rules (Kintner regulations). 2. Who/what is eligible for an election. 3. Treatment of US and foreign entities if there is no election. 4. Election mechanics. 5. Walking through Form 8832. 6. Examining the deemed transactions the election causes. 7. Reviewing the practical impacts of an election so you know the advantages and disadvantages. 8. Discussing the various compliance impacts of the elections, including potential forms to be filed post-election (e.g., 5471, 8865, 8858).

Course key Concept: International tax, Global tax, Entity classification, Check the Box, Election, Association taxable as a corporation, Corporation, Per Se corporation, Partnership, Disregarded Entity, Eligible entity, Form 8832, Late election, Rev Rul 99-5, Rev Rul 99-6, Tax treaty, Tax treaties, Form 5471, Form 8865, Form 8858, Inc, Public Limited Company, AG, KK, Sociedad Anonima, BV, GmbH, Ltd, SRL,

Course Series

This course is included in the following series:

7 CoursesPractical International Tax for the Non-Specialist

  1. Practical International Tax for the Non-Specialist #1: Tax Residency and Foreign Financial Account Disclosures
  2. Practical International Tax for the Non-Specialist #2: Case Study - US Person Earning Foreign Income and then Transferred to Foreign Subsidiary.
  3. Practical International Tax for the Non-Specialist #3: Anti-deferral overview– Subpart F and CFCs.
  4. Practical International Tax for the Non-Specialist #4: US Taxation of Nonresident Individuals
  5. Practical International Tax for the Non-Specialist #5: Section 956, Investment of Earnings in US Property
  6. Practical International Tax for the Non-Specialist #6: Check The Box Overview (Entity Classification Election)
  7. Practical International Tax for the Non-Specialist #7: Foreign Investment in US Real Property - FIRPTA

Learning Objectives

  • Explore the different types of tax entities.
  • Identify why and how the introduction of the check the box rules significantly changed the international tax landscape.
  • Discover how to make a check the box election.
  • Recognize the deemed transactions an election (or change of ownership) causes.
Last updated/reviewed: July 03, 2020

Prerequisites

Course Complexity: Intermediate

No advanced preparation or prerequisites are required for this course. However it is recommended to take other Tax courses by Marc Schwartz: Practical International Tax for the Non-Specialist

Education Provider Information

Company:
Illumeo, Inc., 75 East Santa Clara St., Suite 1215, San Jose, CA 95113
Contact:
For more information regarding this course, including complaint and cancellation policies, please contact our offices at (408) 400- 3993 or send an e-mail to .
Course Syllabus
INTRODUCTION AND OVERVIEW
  6:55Introduction to Practical International Tax for the Non-Specialist #6: Check The Box Overview
  6:50Check the Box Election
  7:49Form 8832
  8:24Entities Change Classification
  4:43Conversions
  6:13Course Wrap Up
CONTINUOUS PLAY
  40:52Practical International Tax for the Non-Specialist #6: Check The Box Overview
SUPPORTING MATERIAL
  PDFSlides: Practical International Tax for the Non-Specialist #6: Check The Box Overview
  PDFPractical International Tax for the Non-Specialist #6: Check The Box Overview Glossary/ Index
REVIEW AND TEST
  quizREVIEW QUESTIONS
 examFINAL EXAM