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Level 5
March 24, 2023
Question

FOREIGN INCOME

  • March 24, 2023
  • 1 reply
  • 22 views

A client owns 10% of a foreign corporation. He received a distribution for his share of income. Where exactly do I report this income? the business is a resort in Belize. there are 10 units that are rented out and include full services on premises. I know if this was an US business it would appear on Form E Part II but there are no US ID numbers so I am at a loss on how to report this on ProSeries...

 

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1 reply

itonewbie
Level 15
March 24, 2023

Direct ownership?  Any indirect and/or constructive attribution?

Do US persons (whether individuals or entities) own more than 50% of the foreign corporation in aggregate?

What is the entity type of the foreign corporation?  Are the liabilities of the shareholders or partners limited?

Does the foreign corporate actively runs the resort as a ToB or merely invest in it?  Is that the only income the foreign corporation has?

I would ask your clients these questions but there could be a whole lot more.

---------------------------------------------------------------------------------Still an AllStar
daroccoAuthor
Level 5
March 24, 2023

Ten investors each owning 10%. Yes, more than 50% is owned by various US investors. CFC corporation. Limited liabilities. The foreign corporation actively runs the resort. That is the only type of income that runs through the entity.

itonewbie
Level 15
March 24, 2023

Someone already prepared the F.5471?  And you have a copy?

---------------------------------------------------------------------------------Still an AllStar