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In this presentation, trace the evolution of the U.S. owners' filing requirements with respect to a foreign startup company over the years as more U.S. owners buy in and the total U.S. ownership increases.
Examine the Form 8621 and Form 5471 filing requirements for each year for each of the US individuals involved. Cover how to make a purging election to tax the startup as a CFC (and not a PFIC) in the final year. Finally, briefly discuss the option of making a QEF election for the pre-CFC years.
CPAs and Attorneys.
Debra Rudd is a CPA at HodgenLaw PC, a boutique international tax law firm in Pasadena. She has a bachelor’s degree in philosophy from Columbia University and is pursuing a master’s degree in taxation at Golden Gate University.
In addition to managing the firm’s day-to-day operations, she prepares complex tax returns for high net worth individuals and various entities. Focus areas include passive foreign investment companies, controlled foreign corporations, foreign trusts, and foreign investment in U.S. real estate. Russ frequently writes and speaks on various crossborder tax topics for HodgenLaw and CalCPA.