Is it common that a US shareholder of a foreign company with 40% combined US shareholder ownership does not need to file 5471? I walked through the filer categories and the taxpayer does not fall under any category. Also checked with taxpayer and there is no other possible ownership (constructive, indirect, etc) to trigger CFC status.
If no 5471 is required under this scenario, are there any other relevant filing obligations?
another questions is that if a non-CFC changed to a CFC, all the calculation of PTEPs, e&p not previously taxed, etc. starts from the time it becomes CFC?
what if for whatever the reason, the CFC turns to a non CFC again, back and forth. I want to have the idea how such changes impact the tracking of all the pteps and reclassifications.