Congress and the Internal Revenue Service continue to increase filing and information reporting requirements on U.S. persons who own interests in foreign entities, transact business with foreign entities and conduct business abroad.

The categories of U.S. persons who are obliged to make these different filings, and the information required by these filings, continuously grows in sweep and complexity. The penalties that can be imposed on U.S. persons who fail to comply with these requirements are among the most severe in the Internal Revenue Code. Added to this is an ever-increasing focus by the Internal Revenue Service on international tax compliance.

Finally, the use of the partnership/pass-through form of entity has exploded over recent years. This combination of more reporting, more complexity, more compliance and greater potential penalties is a potentially toxic brew for the unprepared taxpayer and tax advisor.

This topic will help persons who deal with cross-border pass-through entities be aware of potential filing and reporting obligations and be equipped to comply with them.What You'll Learn:Foreign Partnership Basics

• What Is a "Partnership"?
  
• When Is a Partnership a "Foreign" Partnership?
  
• What About Hybrid Entities?

Key Definitions and Ownership Rules

• What Is a "Us" Person?
  
• How Do the Constructive Ownership Rules Work?

Who Has to File Form 8865

• Control Persons - the Category 1 Filer
  
• U.S. Controlled Partnerships - the Category 2 Filer
  
• Property Contributors - the Category 3 Filer
  
• Acquisitions/Dispositions/Changes of 10% Interests - the Category 4 Filer
  
• Overlapping Categories
  
• Special Situations

Filing Form 8865

• Differences Between Form 8865 and Other Key International Returns Such as 8939 and 5471
  
• Key Elements of the Schedules for Form 8854
  
• How and Where to File Form 8865

Penalties Associated With Form 8865

• Failure to Timely Submit Information
  
• Failure to Properly Report Property Contributions
  
• Failure to Properly Report Changes of Interests
  
• Penalty Abatement Strategies