2021 International Slides 12.09.2021 - FINAL | Page 16

Disclosures

• Forms to be filed

• U . S . ownership in controlled foreign corporations ( CFC ) – Form 5471

• Most complex foreign reporting form

• Annual reporting increased from 30 pages of information per CFC to 50 + pages per CFC

• Country by country reporting of income and foreign taxes for each CFC

• Reporting of all intercompany transactions

• Reporting of previously taxed income

• Taxed on GILTI Income – all CFC income in excess of a specified return of assets

• Foreign Partnership / Branches – Forms 8858 , 8865

• Informational reporting only

• Income flows into US owner tax return

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