Does The Taxpayer Own An Interest In A Foreign Disregarded Entity?
Special reporting rules also apply to U.S. Persons who are owners of a foreign disregarded entity.
Any U.S. Person that is treated as the owner of the assets or liabilities of a foreign disregarded entity is required to file a Form 8858 with its timely filed income tax return, including extensions.
A foreign disregarded entity is simply an entity organized outside the
The disregarded status of the foreign entity is determined under
A U.S. Person that controls a foreign corporation or a foreign partnership, which corporation or partnership owns a foreign disregarded entity, may also have a reporting obligation. A U.S. Person may be required to file a Form 8858, even when (i) the person has no direct ownership in the foreign disregarded entity, and (ii) the constructive or indirect ownership is less than 100 percent.