KS online Form 5472 2023-2025

KS online Form 5472: What You Should Know

S. Company's foreign ownership is any interest of a person in the United States (except as provided in paragraph (d) of this section), whether that interest is expressed in any way in this return. (2) For each reporting company, the Foreign Corporation Identification number (FCI) or the International Corporation Identification number (ICI) assigned to a foreign owned asset must be disclosed in the following places: a. On the company's form 1041 or 1040. b. In the applicable statements of financial position or statement of profits and losses. (3) For purposes of reporting foreign ownership, a related person or affiliate (within the meaning of section 7701(a)(29) of the Internal Revenue Code(Sec. 6671)) is any person who is related to, is controlled by, or is under common control with (or is under common control with in the case of an uncontrolled closely held partnership) the U.S. owner of the foreign owned asset, including a person who has an interest in, shares of common stock in, or bonds, debentures, or other evidences of indebtedness of the U.S. owner of that foreign owned asset. If a U.S. company is not a controlled foreign corporation and the foreign owned asset is not primarily invested in the United States, then any such owner will be a related person or affiliate. For these purposes, a “person” is any individual or partnership, corporation, trust, estate, joint venture, syndicate, or any other entity. (4) A non-U.S. person, such as a foreign government or foreign central bank, does not owe a U.S. tax on such property. However, because a non-U.S. person does not owe U.S. tax on a property unless and until ownership is transferred to a U.S. person, the owner of such property retains the U.S. tax obligations under U.S. law with respect to that property. (5) The purpose of listing the FCI is to encourage corporations to report any non-U.S. person with whom they plan to do business to the IRS. Because of the IRS' enforcement power over U.S. income tax reporting requirements on non-U.S. persons, failure to comply with this paragraph may result in an audit of a U.S. reporting company.

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