1. What is it?
Corporation, partnership, disregarded entity or a branch of the individual under U.S. classification rules.
A U.S. citizen who owns an Indian business may have to report the business, its financial statements, related-party dealings, foreign taxes and some undistributed income. The central filings are Form 5471 for specified interests in foreign corporations, Form 8865 for specified interests and transactions involving foreign partnerships, and Form 8858 for foreign disregarded entities and foreign branches.
Bottom line: The filing form follows the business’s U.S. federal tax classification, not the label printed on an Indian certificate. Determine the U.S.-person start date, classify the business, map direct and constructive ownership, and only then choose Forms 5471, 8865 or 8858. More than one form may apply in a tiered structure.
2. Who owns it?
Direct, indirect and constructive ownership can change control, CFC status and filer category.
3. What happened?
Becoming a U.S. person, crossing 10% or 50%, contributing property, selling an interest or changing classification can trigger reporting.
Zero U.S. tax does not mean zero filing. These are information returns. A dormant, loss-making or cash-poor Indian business can still require a long form, and a return missing required schedules may not be treated as substantially complete.
First establish when U.S. reporting began
Naturalization is not always the first relevant date. A person can become a U.S. tax resident years earlier by meeting the green-card test or substantial-presence test. Resident aliens generally follow the same worldwide-income rules as U.S. citizens. A first-year election, spousal residence election, dual-status year or treaty residence position can alter the analysis.
| Date | Why it matters | Evidence |
|---|---|---|
| Business formation or acquisition | Establishes whether ownership preceded U.S. status and whether later contributions or changes occurred | Certificate, register of members, partnership deed, subscription and purchase documents |
| First U.S. tax-resident day | Can begin worldwide-income and international information-return duties before citizenship | Visa/travel history, green-card date, day count, elections and prior returns |
| Naturalization date | Confirms citizenship but may not be the start of the filing history | Certificate of naturalization and passport |
| Each ownership change | Tests 10% acquisition/disposition events, control and CFC or partnership categories | Share register, cap table, gift or inheritance documents, buyback and transfer forms |
| Classification election or restructuring | Can change the applicable form and create a deemed taxable liquidation or contribution | Form 8832, acknowledgments, resolutions, merger and conversion documents |
A particularly important rule appears in the Form 5471 instructions: a person who becomes a U.S. person while already owning at least 10% of the vote or value of a foreign corporation is a Category 3 filer. That transition event can be missed when an owner assumes that nothing happened because no shares were purchased in the United States.
Part-year complications: A dual-status year can require separate pre-residency and U.S.-residency computations. Do not simply use December 31 ownership and twelve months of financial statements without testing the applicable acquisition, annual-accounting and income-inclusion periods.
The Indian label does not choose the U.S. form
The U.S. “check-the-box” regulations divide business entities into corporations, partnerships and entities disregarded from their owners. Certain foreign entities are corporations by rule. Other eligible entities receive a default classification based on the number of owners and whether members have limited liability, unless a valid election changes that result.
| Indian legal form | U.S. starting point | Likely primary form | What must be verified |
|---|---|---|---|
| Public Limited Company | Listed as a corporation in Treasury Regulation §301.7701-2, subject to a narrow historic deemed-public-company exception | Form 5471 if a filer category is met | Exact corporate form, share ownership, officer/director status, control and CFC status |
| Private Limited Company / OPC | Often a foreign eligible entity that defaults to association/corporation status because its member or members have limited liability | Usually Form 5471; Form 8858 only if eligible, single-owner and validly classified as disregarded | Constitution, shareholder liability, number of owners and Form 8832 history |
| Traditional partnership firm | Often partnership status when it has two or more members and at least one member lacks limited liability | Form 8865 if ownership, control or transaction tests are met | Deed, local law, partner liability, profit/capital rights and any entity election |
| Limited Liability Partnership (LLP) | Not automatically a partnership. If it is eligible and every member has limited liability, the foreign default is association/corporation | Form 5471 under corporate default, or Form 8865 if a valid partnership election applies | LLP statute and agreement, member liability, prior U.S. relevance and Form 8832 |
| Sole proprietorship | No separate owner; the Indian activity may be the individual’s foreign branch or qualified business unit | Form 8858 when the foreign-branch rules apply, plus Form 1040 business schedules | Separate books, business activity, office or fixed place, accounts, assets and employees |
| Single-owner foreign eligible entity | Corporation if the owner has limited liability; disregarded if the owner lacks limited liability, unless elected otherwise | Form 5471 or Form 8858, based on classification | Owner liability and elections—not “one owner” by itself |
Indian LLP trap: “LLP” sounds like “partnership,” but the foreign default rule focuses on limited liability. Filing Form 8865 for an Indian LLP without a classification analysis can leave a required Form 5471 unfiled. Conversely, a timely or late-relief Form 8832 election may support partnership status, but the election and any deemed transactions must be analyzed—not assumed.
Form 8832 is not a harmless label change
An eligible entity may use Form 8832 to elect corporation, partnership or disregarded status where permitted. An election generally cannot be more than 75 days retroactive or 12 months prospective, and another elective classification change is generally restricted for 60 months. A change can create deemed contributions, distributions or liquidations with real tax consequences. Obtain advice before “fixing” a classification after the fact.
The regulations also address when a foreign entity’s classification first becomes relevant for U.S. federal tax. Immigration into the U.S. tax system can make an old Indian entity newly relevant. That is why the historic number of members, their liability and any earlier U.S. owners or filings matter.
Form 5471: ownership of an Indian corporation
Form 5471 is attached to the income tax return by its due date, including extensions. A separate form is generally prepared for each foreign corporation. It can require identifying information, an ownership chart, income statement, balance sheet, currency translation, earnings-and-profits accounts, related-party transactions, foreign taxes and CFC computations.
| Category | Typical trigger | Indian-business example | Filing character |
|---|---|---|---|
| Category 2 | U.S. citizen or resident is an officer or director when a U.S. person acquires stock that reaches 10% vote or value, or acquires another 10% | You remain a director when a U.S. relative or investor crosses the 10% threshold | Event-based; exceptions can apply |
| Category 3 | Specified acquisition, disposition or ownership event involving a 10% vote/value threshold | You become a U.S. person while already owning 25%; buy from 8% to 12%; or dispose below 10% | Event-based and especially important in the immigration year |
| Category 4 | U.S. person controls more than 50% of voting power or total value at any time | You own 60% of an Indian private limited company | Annual control filing with extensive schedules |
| Category 5 | U.S. shareholder generally owning at least 10% vote or value of a controlled foreign corporation | U.S. shareholders collectively own more than 50%, and you own 10% or more | Annual CFC filing; subcategories and attribution rules matter |
| Category 1 | Certain U.S. shareholders of specified foreign corporations under section 965-related rules | May overlap in structures with accumulated post-1986 earnings or other specified-foreign-corporation status | Technical; use the current-year instructions |
Control and CFC status are different tests
Category 4 asks whether the particular U.S. person controls more than 50% of vote or value. CFC status asks whether qualifying U.S. shareholders, applying complex ownership rules, collectively own more than 50% of vote or value. A 40% shareholder may lack Category 4 control but still have Category 5 obligations if the corporation is a CFC. Direct, indirect and constructive ownership—including specified family and entity attribution—can change both answers.
A wholly owned Indian company is not merely a dividend vehicle. It is usually a CFC. The U.S. owner may have current inclusions under Subpart F and section 951A/tested-income rules even when the company pays no dividend. Previously taxed earnings and profits must then be tracked so a later distribution is not taxed twice.
Corporate tax is not automatically the shareholder’s Form 1116 credit
The Indian company pays its own corporation tax. An individual shareholder generally cannot copy that amount to Form 1116 as though the individual paid it. CFC rules contain special foreign-tax and inclusion mechanics. An individual may evaluate a section 962 election in an appropriate year, but it is an annual, computation-heavy choice that can change both current tax and the treatment of later distributions. Compare the result with and without the election, including state tax.
Expect an accounting conversion, not a transcription exercise
Indian financial statements and income-tax returns are evidence, not a completed Form 5471. U.S. rules can differ for depreciation, inventory, revenue recognition, reserves, shareholder loans, related-party payments, foreign-currency translation, earnings and profits, tested income and the timing of deductions. A sole owner may need extensive Schedules C, F, I, I-1, J, M, P, Q and R depending on the filer categories and current-year instructions.
Form 8865: an Indian partnership—or an entity elected as one
Form 8865 reports certain U.S. persons who control, own interests in, transfer property to or have significant ownership changes in a foreign partnership. It is attached to the U.S. income tax return, and a separate form is generally required for each foreign partnership.
| Category | Core test | Example | What follows |
|---|---|---|---|
| Category 1 | U.S. person controlled the foreign partnership—generally more than 50% interest—at any time | You hold 70% of capital and profits in a qualifying Indian partnership | Full partnership reporting, including income, balance sheet, capital, Schedules K/K-1 and often K-2/K-3 |
| Category 2 | U.S. person held at least 10% while the partnership was controlled by U.S. persons each owning at least 10% | Three U.S. persons each own one-third; no Category 1 filer exists under the applicable rules | Annual reporting, subject to overlap rules and exceptions |
| Category 3 | U.S. person contributed property and either held at least 10% immediately after or contributed more than $100,000 in aggregate during a 12-month period | You transfer intellectual property, equipment or cash/property above the threshold to the partnership | Transfer reporting; section 721(c) and gain-deferral rules can add complexity |
| Category 4 | Reportable acquisition, disposition or change in proportional interest, generally involving a 10% threshold or 10-percentage-point change | You move from 9% to 10%, from 12% to 8%, or from 11% to 21% | Event-based ownership reporting |
Control measures more than nominal units. The instructions examine interests in capital, profits, deductions and losses, with attribution rules. A family partnership deed that allocates 5% capital but 55% profits to the U.S. person needs more analysis than its cap table suggests.
Partners report income before cash is distributed
If the entity is a partnership for U.S. purposes, its items generally flow through to the U.S. owner under U.S. tax rules. The U.S. partner needs a Schedule K-1-style computation, tax-basis capital and outside-basis rollforward—even if the Indian partnership keeps books only under Indian accounting standards. Distributions, liabilities, partner loans and contributions then adjust basis under U.S. rules.
A classification error can reverse the whole model. Treating an Indian LLP as a partnership creates flow-through income and Form 8865. Treating it as a corporation can create Form 5471, CFC inclusions and corporate-distribution rules. Resolve the classification before preparing either return.
Form 8858: disregarded entities and foreign branches
Form 8858 is used by certain U.S. persons that directly or indirectly own a foreign disregarded entity or operate a foreign branch. It can also sit beneath Form 5471 or Form 8865 when a CFC or controlled foreign partnership owns the disregarded entity or branch.
| Structure | U.S. treatment | Primary return path | Key schedules or issues |
|---|---|---|---|
| Individual directly runs an Indian sole proprietorship | Activity belongs directly to the individual; may be a foreign branch/QBU | Form 1040, often Schedule C, plus Form 8858 if the branch test is met | Income statement, balance sheet, currency translation, branch losses and Schedule M where applicable |
| Single-owner eligible entity classified as disregarded | Entity ignored for federal income tax, but separately reported as an FDE | Form 8858 attached to owner’s return | Tax owner, direct owner, books, disregarded transactions and related parties |
| Indian company owns a single-member FDE | CFC owns a lower-tier disregarded entity | Form 8858 attached through Form 5471 | Tiered ownership, Schedule M and inclusion in CFC computations |
| Foreign partnership operates an Indian branch | Controlled foreign partnership has branch operations | Form 8858 attached through Form 8865 | Partner-category coordination and branch books |
What is a foreign branch?
A fixed business operation outside the United States can be a foreign branch under the Form 8858 rules, including a foreign qualified business unit in appropriate cases. Separate books and records are highly relevant. A business bank account, GST registration, office, employees, invoices, inventory and a local establishment can support branch status; no single item is conclusive for every rule.
Sole proprietor income still belongs on Form 1040
Form 8858 is an information return; it does not replace the income schedule. A U.S. individual commonly reports the foreign sole proprietorship’s revenue and deductible expenses on Schedule C, translated under U.S. tax rules. U.S. depreciation, capitalization, inventory and business-expense standards apply. Net earnings may also enter the self-employment-tax calculation. Foreign earned income exclusion rules, where available, do not automatically eliminate self-employment tax.
Penalty language needs owner-specific analysis. The Form 8858 instructions describe section 6038 penalties in connection with CFC and controlled-foreign-partnership reporting. Do not assume that every late 8858 for a directly operated individual branch automatically produces the same $10,000 assessment; identify the statutory filing basis, owner chain and applicable penalty provision.
Build a U.S.-ready accounting package
The compliance bottleneck is usually data, not the signature page. Indian books may use a March 31 year-end and Indian accounting/tax classifications, while the owner’s U.S. filing needs the entity’s required annual accounting period, U.S. tax adjustments and functional-currency translation.
| Document | Why the U.S. preparer needs it |
|---|---|
| Formation certificate, memorandum/articles, partnership or LLP agreement | Establishes legal form, members, voting rights, limited liability and classification facts |
| Annual and historic cap table | Tests 10%, control, CFC, acquisition/disposition and attribution dates |
| Trial balance, profit-and-loss statement and balance sheet | Forms the starting point for U.S. schedules and reconciliation |
| General ledger and related-party ledger | Identifies owner loans, compensation, rent, royalties, management fees and Schedule M/N transactions |
| Indian income-tax return, tax audit report and tax-payment evidence | Supports foreign-tax, timing and income reconciliation without treating Indian taxable income as the U.S. answer |
| Bank statements and maximum balances | Supports cash reconciliation, FBAR and signatory/ownership analysis |
| Fixed-asset and depreciation register | Allows U.S. basis, placed-in-service dates and depreciation adjustments |
| Inventory, receivables, payables and provisions | Supports U.S. timing, reserve and balance-sheet adjustments |
| Dividend, distribution, capital-contribution and loan documents | Separates return of capital, dividend, partnership distribution, debt and equity |
| Prior Forms 5471, 8865, 8858, 926, 8938 and FBARs | Preserves consistency, earnings-and-profits, PTEP, tax-basis capital and correction history |
Indian legal documents and books
+ ownership and transaction timeline
+ U.S. classification and tax adjustments
+ functional-currency translation
= U.S. international information return and income computation
+ ownership and transaction timeline
+ U.S. classification and tax adjustments
+ functional-currency translation
= U.S. international information return and income computation
Best practice: Keep a permanent file for classification, ownership, basis, earnings and profits, previously taxed earnings, partner capital, contributions and distributions. Rebuilding these ledgers after a sale or IRS notice is much more expensive than updating them each year.
Why missed information returns are dangerous
International information-return penalties can apply even where the underlying U.S. income tax is small or zero. The penalty depends on the form’s statutory basis and filer category, so the exact exposure should be mapped form by form.
| Failure | Potential starting penalty | Continuation or additional consequence | Important qualification |
|---|---|---|---|
| Form 5471 section 6038 annual reporting | $10,000 for each annual accounting period of each foreign corporation | After 90 days from IRS notice, $10,000 for each 30-day period or fraction, generally up to $50,000 additional per failure; foreign tax credit reduction may apply | Other Form 5471 provisions, including section 6046 events, have separate but similar penalty rules |
| Form 8865 Category 1 or 2 reporting | $10,000 per tax year for each foreign partnership | Notice-based continuation penalties and possible foreign tax credit reduction | Category 3 and 4 use different statutory rules |
| Form 8865 Category 3 property transfer | Generally 10% of the fair market value of contributed property | Generally capped at $100,000 unless intentional disregard; gain recognition can also result | Reasonable cause and section 721(c) requirements require separate analysis |
| Form 8865 Category 4 ownership event | Generally $10,000 per reportable event | Additional notice-based continuation penalties can apply | Acquisition, disposition and proportional-change rules must be tested separately |
| Form 8858 | Section 6038 failures in CFC/controlled-foreign-partnership chains can begin at $10,000 | Continuation penalties, foreign tax credit reduction and other consequences may apply | A directly owned individual branch requires analysis of the precise filing and penalty authority |
| Form 926 | Generally 10% of fair market value of transferred property | Generally capped at $100,000 unless intentional disregard | Reasonable cause and not willful neglect can provide relief |
The assessment period can remain open
Under section 6501(c)(8), failure to provide required international information can extend the assessment period until three years after the information is furnished. The scope of the extension can depend on whether the failure was due to reasonable cause and not willful neglect. This is a reason to address a missing form promptly instead of waiting for a cash-tax audit.
Incomplete can be treated like unfiled
A name, address and balance sheet are not necessarily a substantially complete Form 5471 or 8865. Required schedules vary by category. Omitting the ownership chart, related-party transactions, CFC schedules, partner information or a lower-tier Form 8858 can leave penalty exposure even if the main form was physically attached.
Do not file a bare “protective” form without analysis. A wrong entity classification, wrong filer category or materially incomplete schedule may fail to start the intended limitations period and can create inconsistent positions in later years.
What to do when old forms were missed
The correct route depends on whether income was omitted, whether tax was underpaid, whether the taxpayer is under examination or has been contacted, and whether the conduct was non-willful or potentially willful. Do not select a compliance procedure from a blog checklist alone.
- Freeze new inconsistencies. Identify the correct U.S. classification before filing the current year. Do not repeat a possibly wrong Form 8865 or 5471 solely for consistency.
- Reconstruct the first U.S.-person year. Determine the green-card, substantial-presence, election or citizenship start date and every later ownership event.
- Prepare a form-by-form exposure map. List Forms 5471, 8865, 8858, 926, 8938, 8621 and FBAR by year, entity and legal provision.
- Recompute income and tax. Test CFC inclusions, partnership or branch income, dividends, distributions, foreign tax credits and self-employment tax.
- Evaluate the proper compliance path. Consider normal amended-return procedures, reasonable cause, streamlined filing compliance or voluntary disclosure only with advice suited to the facts.
- Make each submission complete. Attach the required information returns to the amended income tax return where directed, preserve proof of filing and keep the legal and factual support.
- Respond carefully to notices. An initial penalty assessment may not reflect every reasonable-cause fact. Calendar deadlines and answer the exact statutory penalty asserted.
The IRS’s current delinquent international information return procedures state that eligible taxpayers not under civil examination or criminal investigation and not already contacted about the delinquent returns should use normal filing procedures. Except for Forms 3520 and 3520-A, delinquent international information returns are attached to an amended income tax return. Penalties may be assessed, and a reasonable-cause statement may be attached where asserted.
Reasonable cause is evidence-based. It is not a magic caption. The explanation should address the taxpayer’s background, advice received, information provided to the adviser, steps taken to understand the duty, timing of discovery and speed of correction. Reliance on a preparer is not automatically sufficient.
Four common ownership examples
Example 1: 100% owner of an Indian private limited company
Meera formed an Indian private limited company before moving to California. She became a U.S. tax resident under the green-card test in 2024 and became a citizen in 2026. Assuming U.S. corporate classification, the 2024 transition can be a Category 3 event, and more-than-50% control generally creates Category 4 reporting. The company is likely a CFC, so Category 5 reporting and current-income computations may also apply. Her 2026 naturalization did not begin the filing duty.
Example 2: 40% of a family company
Arjun owns 40%; his U.S.-person sister owns 20%; Indian-resident relatives own the rest. Arjun does not individually control more than 50%, but the corporation may still be a CFC because qualifying U.S. shareholders collectively own more than 50%. Attribution and the exact vote/value rights must be tested. Form 5471 may apply even though Arjun cannot unilaterally run the company.
Example 3: 50% member of an Indian LLP
Ravi’s adviser calls the LLP a partnership and prepares Form 8865. If every member has limited liability and no valid classification election exists, the foreign default may instead be association status taxable as a corporation. The correct result could be Form 5471. Ravi needs the LLP statute and agreement, member-liability analysis, U.S.-relevance date and election history before choosing the form.
Example 4: consulting practice in India
Leena personally owns a consulting practice with Indian GST registration, a leased office, employees, separate books and a business bank account. It is not a separate company. She generally reports the business income directly on Form 1040, often Schedule C, and tests whether the operation is a foreign branch requiring Form 8858. She also tests the business bank account for FBAR and Form 8938 under their separate rules.
Annual filing checklist
- Confirm the first U.S.-person date and whether the year is full-year or dual-status.
- Update the direct, indirect and constructive ownership chart for every entity tier.
- Document the U.S. classification and every Form 8832 election or deemed transaction.
- Identify each Form 5471, 8865 and 8858 filer category—not merely the form number.
- Obtain year-end books, general ledger, tax return, bank records and an ownership-event timeline.
- Convert Indian accounts to U.S. tax concepts and the required functional/reporting currency.
- Compute CFC, partnership or branch income even if no cash was distributed.
- Reconcile Indian taxes to the person who legally paid them and the U.S. income category.
- Test Form 926, Form 8938, FBAR, Form 8621 and other connected filings independently.
- Review related-party payments, shareholder/partner loans, capital contributions and distributions.
- Confirm that every required schedule is substantially complete and internally consistent.
- Preserve classification, basis, earnings-and-profits, PTEP and partner-capital workpapers permanently.
Before restructuring or selling: Model the U.S. tax effects first. Converting an LLP, checking the box, liquidating a company, transferring IP, admitting a U.S. family member, paying a dividend or forgiving a shareholder loan can produce both tax and new reporting events.
Ten common mistakes
- Starting with citizenship. Earlier green-card or substantial-presence years are ignored.
- Translating the Indian label. “LLP” becomes partnership and “one-person company” becomes disregarded entity without applying U.S. classification rules.
- Looking only at year-end ownership. An acquisition, disposition, control or transfer event during the year is missed.
- Ignoring attribution. Family and entity ownership rules are excluded from the CFC, control or partnership analysis.
- Reporting only dividends. CFC, partnership or branch income that may be taxable before distribution is omitted.
- Claiming company tax on Form 1116. Indian corporate income tax is treated as though the individual paid it directly.
- Filing the shell but not the schedules. The return is not substantially complete for the filer category.
- Forgetting lower tiers. A company or partnership owns an FDE or branch that requires Form 8858.
- Assuming FBAR or Form 8938 substitutes. Separate information-return duties are never tested.
- Correcting casually. A delinquent form is mailed alone without analyzing amended-return procedures, omitted income, reasonable cause or the proper compliance path.
Frequently asked questions
Does every Indian private limited company require Form 5471?
No. The entity must first be classified as a foreign corporation for U.S. tax purposes, and the owner must meet a Form 5471 filer category. A U.S. person who owns more than 50% usually has a Category 4 control filing and may also have a Category 5 CFC filing; a 10% owner can have event-based or CFC-related filing depending on the facts.
Is an Indian LLP automatically a partnership for U.S. tax purposes?
No. The U.S. classification rules, not the Indian label, control. A foreign eligible entity whose members all have limited liability defaults to association status taxable as a corporation unless a valid Form 8832 election changes the result. Review the LLP statute, agreement, member liability and election history.
What if I owned the Indian company before I became a U.S. person?
Becoming a U.S. person while already owning at least 10% of a foreign corporation is a Form 5471 Category 3 event. The relevant date may be when U.S. tax residency began under the green-card or substantial-presence test, not the later naturalization date. The first U.S. year can also begin CFC income and annual reporting.
Does an Indian sole proprietorship require Form 8858?
It can. A directly operated sole proprietorship is not a separate corporation or partnership, but its activities may constitute a foreign branch or qualified business unit. The owner generally reports the business on Form 1040, often Schedule C, and tests Form 8858 separately. Separate books and records are important but not the only fact.
Can Indian company tax be claimed directly on my Form 1116?
Usually not merely because the individual owns the company. A corporation is a separate taxpayer, so its Indian corporate tax is not automatically the shareholder’s direct foreign tax credit. Special deemed-paid credit rules may become relevant with CFC inclusions and, for an individual, sometimes a section 962 election, but those rules require a separate computation.
Does a dormant or loss-making Indian business avoid these forms?
Not necessarily. Forms 5471, 8865 and 8858 are driven by classification, ownership, control, transfers and operations—not only profit or cash distributions. A dormant entity may still have share capital, accounts, related-party balances or a reportable ownership event.
What are the penalties for missing Forms 5471, 8865 or 8858?
Many section 6038 failures start at $10,000 for each annual period and each foreign entity, with additional $10,000 increments after an IRS notice, generally capped at $50,000 of continuation penalties per failure. Transfer and ownership-event provisions have different penalties, including percentage-of-property penalties in some cases. Reasonable-cause standards and the legal basis for each form matter.
Do FBAR or Form 8938 replace Forms 5471, 8865 or 8858?
No. These regimes have different purposes and thresholds. Form 8938 may permit abbreviated treatment for an interest already reported on a specified international form, but the filer generally identifies that form in Form 8938 Part IV. FBAR separately tests foreign business bank accounts for financial interest or signature authority.
Primary sources and further reading
- IRS — Instructions for Form 5471
- IRS — Instructions for Form 8865
- IRS — Instructions for Form 8858
- eCFR — 26 CFR §301.7701-2, Business Entities; Definitions
- eCFR — 26 CFR §301.7701-3, Classification of Certain Business Entities
- IRS — About Form 8832, Entity Classification Election
- IRS — Form 926 Filing Requirement for U.S. Transferors
- IRS — Comparison of Form 8938 and FBAR Requirements
- FinCEN — Report Foreign Bank and Financial Accounts
- IRS — Delinquent International Information Return Submission Procedures
- IRS — Topic No. 851, Resident and Nonresident Aliens