Tax Classification of Foreign Entity

Technical topics regarding tax preparation.
#1
art2670  
Posts:
35
Joined:
29-Mar-2016 9:10am
Location:
Brooklyn NY
Hello,

Looking on some advice with regard to default classification and check the box rules. Here is fact pattern.

My client is deemed owner of his father’s foreign LLC due to constructive ownership rules. I am trying to figure out how to get my client out of 5471 filing requirement (the entity’s default classification under 301.7701-3 is corporation).
Is it possible to file 8832 to elect disregarded treatment for this foreign LLC? I am thinking that if this entity is treated as disregarded then my client does not need to deal with information reporting nonsense.
If so, not sure how to procedurally achieve it, given that the LLC and the father (direct owner) do not have US EIN/ITIN.
 

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