Foreign Entity Classification: Trusts, Business Entities, and Elective Provisions (Completed)

Foreign entities can be subjected to United States income tax requirements when their income is effectively connected to the United States. Such entities can create tax and reporting requirements for United States-based stakeholders as well. An often overlooked — and unfortunately, often oversimplified consideration — is how the foreign entity is classified for United States tax purposes. Critically, the United States maintains its own distinct rules for the classification of foreign entities, and those rules are in no way impacted by how the entity is taxed in its home jurisdiction! Join this webinar for an in-depth discussion of the relevant considerations in this context, including tax ramifications for foreign trusts, foreign corporations, and foreign pass-through entities.

Topics Covered

• Entity Classification Basics — Entity Existence
• Is the Entity a Foreign Trust?
• Foreign Business Entities and their Classification
• Elective Options/Provisions for Foreign Entities
• Anti-Deferral Rules for United States Stakeholders of Foreign Corporations

Learning Objectives

• Recognize how the United States classifies foreign entities
• Identify the tax ramifications associated with interests in foreign trusts and foreign business entities

Level
Basic

Instructional Method
Group: Internet-based

NASBA Field of Study
Taxes (2 hours)

Program Prerequisites
None

Advance Preparation
None