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Actual Tax Law

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5471s and cCorps
I'm a US citizen, MFJ. When I have to file a 5471 for an offshore company I personally own (or co-own as a CFC), it goes with my 1040. I hate this because it mixes in the $25K deadline with my personal return. It also means I can't efile my 1040, and this is a real pain when my husband and I are on different continents when it's time to file our personal tax returns. So here is the question: If my C Corp owns a foreign corp instead of me owning it, does this get it disconnected from my personal return? Would the 5471 be filed with my 1120 instead?
Can a Partnership Representative Use a Registered Agent address?
As I do business internationally and travel constantly, I find it nerve wracking that any IRS notice would come to my US residence where the mail is unreliable and is not automatically scanned. I'm the Partnership Representative for multiple LLCs either as a Managing Member or a Manager (non owner). Today some AI Chatbots told me I could use my LLC's registered agent address as my address for mail that comes to me as a Partnership Representative. In other words: - My legal residence: Address A, State A - My registered agent: Address B, State B The idea would be that where I fill in my address AS the Partnership Rep (not on the K-1 or where I put my personal address) I could use Address B. Then on the K-1 I would still put my residential Address A. If that's correct, it would make life so much easier since I am usually traveling abroad. Is it okay to do this?
8804s/8805s and ECTI
If an LLC is not ETBUS (Engaged in a Trade or Business Inside the United States) is it still possible for it to have ECTI and be required to file 8804/8805 for its foreign partners? The reason I ask is that I got a communication from a CPA once hinting that I had to file 8804/8805s for ANY LLC with foreign partners (even with zero income). The LLC he was filing the return for was not ETBUS. Later I came across contrary info, indicating I only need to file 8804s if there is ECTI. Either there is info to back up the CPA's statement (which I can't find), or he was speaking sloppily and not accurately (and forgetting that the LLC was not ETBUS).
0 likes • Oct '25
@Paola Moreno Thank you!
0 likes • Dec '25
@James Baker thank you, that’s very helpful! Would you even do it with a MMLLC that hasn’t made money yet? Ie a 1065 with all zeros?
BOI requirements
Hello James, My LLC was formed on October, 2025, and I was planning to file the BOI report. However, FinCEN’s March 26, 2025 update says that all U.S.-created entities are now exempt from BOI reporting under the new interim rule. Could you please confirm that I do not need to file the BOI report at this time? Thank you in advance!
0 likes • Nov '25
@Paola Moreno In May/June when I tried to file a BOIR for a Florida LLC owned by a Florida resident (US citizen), the BOIR system gave me a message that the fiings for domestic LLCs are no longer required. Later I encountered a similar problem when trying to ammend due to a new DBA. I'm curious why you are saying what you wrote above. Are you referring to foreign-owned entities?
5472 and Married Couples
Let's say I (US citizen) form a US (Wyoming) C Corp and add a UK resident/citizen as an owner. As long as I keep their ownership under 25%, I don't have to file the 5472. But what if they are married and I give them each 20%? Do I have to file 5472 because their combined ownership is over 25%, and they are married? Or is it based on individual ownership being under 25%?
0 likes • Oct '25
@Paola Moreno Thanks! Yes, that was what I was wondering. Did you see that in the 5472 instructions, or in more general instructions?
1-9 of 9
Ayla May
2
14points to level up
@ayla-may-5097
I am a US citizen living abroad, writing a curriculum, running a nonprofit & several for-profits in the field of education. My focus is on literacy.

Active 3d ago
Joined Aug 25, 2025
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