Partnerships & Shareholders Inclusions from Foreign Corporations

Pass-through entities, owners of foreign stock, and their tax advisors should be aware of IRS guidance on treatment of income inclusions from foreign corporations.

Understand the Tax Implications

IRS regulations (T.D. 9960) finalize an aggregate approach regarding domestic partnerships that own stock of controlled foreign corporations (CFCs) and the treatment of income inclusions from CFCs. Changes took effect January 25, 2022, and retroactive adoption is allowed for post-2017 tax years (under certain conditions).

QUESTION 1

IRS Final Regulations

QUESTION 2

Owners of Foreign Stock

QUESTION 3

Controlled Foreign Corporations (CFCs)

Partnerships & Shareholders Inclusions from Foreign Corporations

Pass-through entities, owners of foreign stock, and their tax advisors should be aware of IRS guidance on treatment of income inclusions from foreign corporations.

Understand the Tax Implications

QUESTION 1

IRS Final Regulations

QUESTION 2

Owners of Foreign Stock

QUESTION 3

Controlled Foreign Corporations (CFCs)

QUESTION 4

Schedule K-2
(Form 1065)

Partnerships & Shareholders Inclusions from Foreign Corporations

Pass-through entities, owners of foreign stock, and their tax advisors should be aware of IRS guidance on treatment of income inclusions from foreign corporations.

Understand the Tax Implications

QUESTION 1

IRS Final Regulations

QUESTION 2

Owners of Foreign Stock

QUESTION 3

Controlled Foreign Corporations (CFCs)

QUESTION 4

Schedule K-2(Form 1065)

Schedule K-2
(Form 1065)