Form 5471, GILTI tax and Deemed Repatriation tax

Technical topics regarding tax preparation.
#1
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an S corp, owned a single member LLC, and this LLC invest 4 overseas companies ( three corps, one LLC) , ownership are over 50%, not Subpart F income.

Questions:
1. does this S corp need to file form 5471 for each foreign companies? I read the instruction, looks like 5471 is filed when US persons own foreign corp 10% or above, not when US corporations own foreign corp? or this US person included US corp?

2.Gilti: will be on 2018 tax return, right?
3. Repatriation Tax:

the four oversea companies: one has accumulated earnings over 1million, the other threes are in small loss. So will have repatriation tax in 2017, right?

Based on my understanding, Repatriation Tax will be taxed on 1040, not in the 1120s, correct?

pretty complicated: Repatriation Tax can be paid in 8 installment payments, but how to do new earnings or next year, each new earnings do a new installment? I check the form , no lines for that.
and there is a lot of elections, headache!
Thanks for help!
 

#2
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OK, 5471 shall be required .

Form 965 will be filed in S corp level.
 

#3
novacpa  
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962 too?
Add Schedule B - check the box "Yes and Yes" report the bank accounts if more than $10k.
PS: I was at the Paul Manafort Trial for a day - the Prosecutors made a big deal of this
they said, "its a felony not to include Schedule B" (even if you have no interest/dividends to report).
Paul's CPA - Cindy Laporta didn't include the form. A felony charge for neglecting to declare foreign bank accounts.
 

#4
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novacpa, that means those bank accounts to be reported twice? one in the 1120s and one in FBAR under signature authority category?
 

#5
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If the foreign LLC is considered a partnership under the Treas Reg 301.7701-3(b)(2), you would file an 8865 not a 5471, just an FYI.
 

#6
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ManVsTax, thank you for the reminder, I overlook it. will see whether is considered a partnership. US company contribute 100% capital but gave local person 20% ownership to meet the local ownership requirement.
 


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