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!