On Dec. 12, 2016, the Treasury Department and the Internal Revenue Service announced final regulations (issued in proposed form on May 5, 2016) requiring domestic disregarded entities with foreign owners to file Form 5472 information returns with the IRS identifying their foreign owners and reporting certain related party transactions.1 Such entities will continue to be disregarded for most federal tax purposes, but they’ll be treated as corporations for purposes of the reporting, record-keeping and other compliance requirements imposed on certain domestic corporations with foreign owners under Section 6038A of the Internal Revenue Code.2 These new reporting requirements arise against a backdrop of increasing multilateral efforts to combat tax evasion and money laundering across borders and growing pressure on the U.S. government from other countries to make it harder for foreign nationals to use U.S. shell companies to hide assets from tax authorities back home.
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