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U.S. Companies with Overseas Subsidiaries

U.S. companies and owners with subsidiaries in China, Hong Kong or elsewhere: Forms 5471 and 8858, GILTI and Subpart F income, and foreign tax credits.

What is included

  • Forms 5471, 8858 and 8865 for the foreign entities
  • GILTI, Subpart F and Section 250 deduction calculations
  • Foreign tax credits at the corporate level
  • Check-the-box elections (Form 8832) when they help
  • Repatriation and dividend planning

Income you did not receive can be taxable

Under GILTI and Subpart F, a U.S. shareholder can owe U.S. tax on a foreign subsidiary’s profits before any dividend is paid. Structure and elections make a large difference.

Common questions

Is it different for an individual owner?

Yes — individuals face GILTI without some corporate benefits, and elections such as Section 962 may help. We compare the options.

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