questions from foreign-owned single member LLC

Technical topics regarding tax preparation.
#1
juro  
Posts:
918
Joined:
18-Oct-2015 9:11am
Location:
USA
1. Would it be more tax efficient if Siguary llc was owned by a UK company ? I have a property company’s the UK called Siguary llc ltd so could transfer ownership to that.

2. Would it be more tax efficient if Siguary llc had more members ?
 

#2
deniz  
Posts:
336
Joined:
19-Feb-2018 11:33pm
Location:
WA
If the client is relatively young, single owner that does short term flips of property, you can leave it as an LLC for the single level of taxation and capital gains tax rate.

All other scenarios are a planning exercise that requires more details of facts and circumstances.
 

#3
swgordon  
Why would you want to have a foreign owner of a US business unnecessarily? You then open yourself up to all the foreign owner reporting. Penalties of which are huge if you fail to file the required forms.
 

#4
juro  
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918
Joined:
18-Oct-2015 9:11am
Location:
USA
swgordon wrote:Why would you want to have a foreign owner of a US business unnecessarily? You then open yourself up to all the foreign owner reporting. Penalties of which are huge if you fail to file the required forms.



https://imgur.com/a/UUfWqjW
 

#5
swgordon  
Exactly. $25k penalty. It is crazy.
 

#6
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20
Joined:
17-Dec-2019 4:15pm
Location:
FL
i have a client who opened up a llc single member on 2021, his EIN state disregarded entity, does he needs to file 1040NR and just tax capital gains? he invested money to build homes and sale them. i don't want him to get a fine of $25k
 

#7
sjrcpa  
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6475
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23-Apr-2014 5:27pm
Location:
Maryland
May be ordinary income instead of capital gain.
Maybe start a new thread and provide more info.
 

#8
Nilodop  
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18757
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21-Apr-2014 9:28am
Location:
Pennsylvania
The LLC disregarded entity owned by a foregn owner still has to file a 5472. https://www.irs.gov/irb/2017-03_IRB#TD-9796
 

#9
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8155
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4-Mar-2018 9:03pm
Location:
The Office
US SMLLC owned by a nonresident alien would file a 5472 for the LLC (informational) and a 1040-NR to report the taxable income.

Assuming DRE of course. Might make a lot of sense to elect "C" for the LLC depending on the facts.
 


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