Classification of Nonresident Entities

Learning Objectives

• To discuss threshold-level considerations for Taxpayer Classification.
• To analyze Foreign Business Entities.
• To explain Foreign Corporations.
• To discuss different aspects of Foreign Corporations.
• To analyze taxation of Foreign Business Entities.

Course Description

A nonresident organizational structure with United States connections is subject to the American tax classification. Classification of foreign interests for U.S. tax purposes is critical, as it dictates the scope of U.S. tax ramifications. U.S. classification does not rely on foreign laws for classification purposes.

Why does classification matter?

Both reporting requirements and the need for/timing of income recognition are largely dictated by entity classification which is why classification matters.

The classification of non-residency status is determined by set circumstances, such as the amount of time spent within a given region during the calendar year. This classification depends on where the person resides and does not focus on citizenship.

Speaker Patrick McCormick in this CE/CPE course covers the classification of nonresident entities for United States tax purposes.

The following are the major topics covered in this online taxation course:

• Threshold Considerations
• Is the Entity a Trust?
• Foreign Business Entities
• Foreign Business Entities - Entity Classification
• Foreign Business Entities - Elections
• Foreign Business Entities - Relevance Determinations
• Taxation of Foreign Business Entities
• Foreign Corporations - Subpart F Income
• Foreign Corporations - GILTI
• GILTI – Regulatory Guidance
• Foreign Corporations - Passive Foreign Investment Companies

Coverage of this CE tax webinar begins with the classification of organizations as separate from taxpayers and then discusses classification differentiations between trusts and business entities.

If you are interested in tax and tax updates, you can access our Latest Tax Update Courses. 

Overview

• Hypothetical fact pattern

  4 mins
• Threshold considerations

  8 mins
• Is the entity a trust?

  17 mins
• Foreign business entities - Entity classification

  45 mins
• Taxation of foreign business entities

  70 mins
• Foreign corporations - Passive foreign investment companies

  93 mins