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Where do I report dividends paid on Form 5471 Schedule C or Schedule F

 

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Subject Author Date
Where do I report dividends paid on Form 5471 Schedule C or Schedule F A Wieser 03-12-2008
Posted by jmail7 on March 12, 2008, 9:56 pm
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> True, that's there on Schedule M, line 21, but it's only true for category 4
> filers.

Note that if the foreign corporation is not controlled by U.S. persons
and you are not a category 4 filer, then you need to assess whether
the foreign corporation is a passive foreign investment company
(PFIC). If it is a PFIC, then you may want to make a qualified
electing fund (QEF) election or a mark-to-market election.

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Posted by A Wieser on March 13, 2008, 10:32 am
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>> True, that's there on Schedule M, line 21, but it's only true for
>> category 4
>> filers.
>
> Note that if the foreign corporation is not controlled by U.S. persons
> and you are not a category 4 filer, then you need to assess whether
> the foreign corporation is a passive foreign investment company
> (PFIC). If it is a PFIC, then you may want to make a qualified
> electing fund (QEF) election or a mark-to-market election.
>

Because of the cash holding to keep the company solvent, it looks like I'm
caught by the PFIC rules, and therefore have to fill out form 8261. However
dividends haven't been over the excess level, except by a few hundred
dollars due to foreign exchange rate movements.

As a result, it looks like it's best not to go with the QEF election.

So, when I go back and allocate the excess on a gain, it says that I should
use the highest rate of tax under section 1 or section 11 for a given year.

Where would I find the tax rates applicable for a given year? Are they in
the 1040 instructions for each year?

Tony

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<< The foregoing was not intended or written to be used, >>
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<< that may be imposed upon the taxpayer. >>
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<< to this newsgroup as well as our anti-spamming policy >>
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Posted by jmail7 on March 13, 2008, 11:21 pm
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> As a result, it looks like it's best not to go with the QEF election.

If you don't make the QEF election you may be effectively converting
capital gain into ordinary income. Other adverse consequences may
also apply.

> So, when I go back and allocate the excess on a gain, it says that I should
> use the highest rate of tax under section 1 or section 11 for a given year.
>
> Where would I find the tax rates applicable for a given year?  Are they in
> the 1040 instructions for each year?

Yes, the section 1 rates are in the tax tables. For individuals the
section 1 rates apply.

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<< ------------------------------------------------------- >>
<< The foregoing was not intended or written to be used, >>
<< nor can it used, for the purpose of avoiding penalties >>
<< that may be imposed upon the taxpayer. >>
<< >>
<< The Charter and the Guidelines for submitting posts >>
<< to this newsgroup as well as our anti-spamming policy >>
<< are at www.asktax.org. >>
<< Copyright (2007) - All rights reserved. >>
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Posted by Alan on March 12, 2008, 8:19 pm
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A Wieser wrote:
>>> The only thing I'm not sure about is where to report the dividends
>>> paid by the company on 5471 schedule C.
>>>
>>> Alternatively, are they just not listed at all, and assumed to have
>>> been paid as the difference between beginning retained earnings and
>>> final retained earnings?
>>>
>>> Tony
>>>
>> Typically, it's buried in the difference between Line 20a and 20b on
>> Schedule F.
>
> That was what I assumed. Thanks for the corroboration.
>
> Tony
>
By the way... the word "Typically" in my response was meant to
imply that GAAP says it is reflected in the retained earnings
delta. I have no idea how a foreign corporation operating out of
a foreign country with accounting procedures not consistent with
US GAAP accounted for it.

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<< ------------------------------------------------------- >>
<< The foregoing was not intended or written to be used, >>
<< nor can it used, for the purpose of avoiding penalties >>
<< that may be imposed upon the taxpayer. >>
<< >>
<< The Charter and the Guidelines for submitting posts >>
<< to this newsgroup as well as our anti-spamming policy >>
<< are at www.asktax.org. >>
<< Copyright (2007) - All rights reserved. >>
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