Appendices
Appendices
United States Tax Laws – A Perspective for Foreign Companies and Individuals Doing Business or Living in the United States
Appendices
Flowchart for determining residency status
Copies of forms 1001, 1040, 1040NR, 1042, 1042S, 5471, 5472, 8300 and TD F 90-22.1
Appendix 2
Forms
1001- Ownership, Exemption, or Reduced Rate Certificate
1040 US Individual Income Tax Return
1040 NR- US Nonresident Alien Income Tax Return
1042 S-Annual Withholding Tax Return for US Source Income of Foreign Persons
1042-Annual Withholding Tax Return for US Source Income of Foreign Persons
5471-Information Return of US Persons With Respect to Certain Foreign corporations
5472-Information Return of a 25% Foreign Owned US Corporation or a Foreign Corporation Engaged in a US Trade or Business
8300-Report of Cash Payments Over $10,000 Received in a Trade or Business
TDF 90-22.1 Report of Foreign Bank and Financial Accounts
“C” Reorganization
“C” Reorganization The target corporation must liquidate as part of the plan of reorganization unless the IRS waives this requirement.’ As a result, the shareholders of the target corporation become shareholders in the acquiring corporation. In determining the tax consequences to the liquidating target, the reorganization provisions govern-not the liquidation rules of §§ 336 and…
“D” Reorganization
“D” reorganization: “Spin-off” and “Split-off” acquisitive d reorganization “D” Reorganization Explanation: * Corporate T contains the assets of former corporation A and of T. * Corporation A goes out of existence Corporation A’s shareholder’s control Corporation T. Requirements for Divisive “D” d reorganization requirements imposed by IRC §355 * Distribution of Control -by the…
“E” Reorganization
“E” Reorganization The “E” reorganization is defined as a re-capitalization – the exchanges of stock and securities for new stock and/or securities by the corporation’s shareholders. It involves only one corporation and the re-configuration of its capital structure. Stock for stock Differences in the voting rights, dividend rates, and preference on liquidation are ignored. Bonds…
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