deniz wrote:Yes, assuming US Corp is 100% owner of CFC. (Its 10% shareholder of the CFC, not of the US Corp).
How does this conclusion reconcile with post 11 above:
"from bottom of page 5 top of page 6 form 5471 instructions - Certain constructive owners not need to file if a category 1,3,4,5, if
1.
The shareholder does not own a
direct interest in the foreign corporation.2. The shareholder is required to
furnish the information requested solely
because of constructive ownership (as
determined under Regulations section
1.958-2, 1.6038-2(c), or 1.6046-1(i)) from
another U.S. person.
3. The
U.S. person through which the
shareholder constructively owns an
interest in the foreign corporation files
Form 5471 to report all of the required
information.No statement is required to be attached
to tax returns for persons claiming the
constructive ownership exception.
As I read this it sounds like if the US partnership which owns 100% of the foreign corp files the 5471, the US partner has no additional disclosure requirement.
Is this correct?