As foreign ownership of U.S. assets through Limited Liability Companies (LLCs) becomes increasingly common, understanding the nuanced tax obligations and potential pitfalls is crucial.

This comprehensive course offers a deep dive into the complexities of LLC taxation, including the distinctions between different types of income, the implications of the U.S. tax treaties, and the critical role of entity classification decisions. Participants will learn strategies to identify and mitigate tax risks, prevent penalties such as the $25,000 penalty for Form 5472, and ensure compliance with U.S. tax law while optimizing investment structures.

Attendees will gain the insights needed to navigate the hidden dangers of LLC taxation and make informed decisions regarding their U.S. investments.

Learning Objectives:

• Outline the U.S. taxation system as it applies to foreign investors owning assets through LLCs, including how profits, dividends, and capital gains are taxed


• Identify the intricacies of filing Form 5472 for foreign-owned U.S. LLCs, including who must file, reporting requirements, and how to accurately disclose transactions between the LLC and related foreign parties


• Evaluate how the choice between 'disregarded entity' and 'corporation' status for an LLC impacts tax obligations and reporting requirements for foreign investors, and how to make the best decision based on specific investment scenarios


• Recognize the common tax pitfalls and compliance risks associated with foreign ownership of U.S. LLCs, including ways to avoid penalties and ensure tax efficiency through strategic planning and structuring

NASBA Approved

CPAacademy.org (Sponsor Id#: 111889) is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its website: www.nasbaregistry.org.

CPAacademy.org 1685 S. Colorado Blvd, Suite #205, Denver, CO 80222

EA Approved

CPAacademy.org (Sponsor Id#: HURS9) has entered into an agreement with the Internal Revenue Service, to meet the requirements of 31 Code of Federal Regulations, section 10.6(g), covering maintenance of attendance records, retention of program outlines, qualifications of instructors, and length of class hours. This agreement does not constitute an endorsement by the IRS as to the quality of the program or its contribution to the professional competence of the enrolled individual. Credit earned by attendees with a PTIN will be reported directly to the IRS as required of all providers. To ensure your CPE hours are reported, update your profile in My Account to include your PTIN number. Please note: IRS CE is only mandatory for EAs and ERPAs. For all other tax return preparers, CE is voluntary.

CPAacademy.org 1685 S. Colorado Blvd, Suite #205, Denver, CO 80222