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To report certain international income, credits, deductions and other miscellaneous items, the IRS has released the final versions of two new forms, which should be added to the tax returns of pass-through entities. For tax years beginning in 2021, if a partnership has items of international tax relevance, it must file Schedule K-2 and Schedule K-3. Schedule K-2 reports partners’ total international distributive share items, whereas partner’s share of international income, credits, deductions etc are reported using Schedule K-3.
Schedules K-2 and K-3, required for tax years 2021 onward, require partnerships, S corporations, and stakeholders in foreign partnerships to report items of “international tax relevance”. While this information has historically been required to be disclosed by reporting entities, formalization of these requirements through the Schedules has led to additional entity-level burdens. Buttressing these burdens is the expansive scope provided by the Service for the Schedules, necessitating reporting by entities without foreign activities or nonresident stakeholders. The information subject to reporting is expansive – arguably any item covered by an Internal Revenue Code international tax provision (directly or indirectly) is subject to disclosure by a reporting taxpayer.
Join us on Compliancevent this October to learn everything you need to know before filing Schedules K-2 and K-3.
-Which entities are required to file Schedules K-2 and K-3?
-What are the specific parts of Schedules K-2 and K-3 and who is required to complete them?
-What are the relief options for failures to properly complete Schedules K-2 and K-3?
-What are the retroactive relief options for stakeholders who previously did not report foreign assets?
-What are the items of international tax relevance?
-What are the parts of Schedules K-2 and K-3?
-Where do requirements exist even without international activities?
If you are a practitioner that represents reporting entities – S corporations, partnerships, and Form 8865 filers, this training will be more than beneficial for you. This program will assist in ascertaining whether Schedules K-2 and K-3 are required to be filed, and which parts require completion if so.
Practitioners with reporting entity clients will benefit as will stakeholders in those entities (or practitioners representing those stakeholders)
Patrick McCormick is an attorney with over
a dozen years of experience, focusing his practice specifically on
international taxation. Mr. McCormick represents both business and individual
clients on all aspects of United States international tax rules, both from an
income tax and estate/gift tax perspective. He collaborates with Clatid
Compliance to help the tax practitioners and professionals stay current and
compliant.
Having previously served as a partner at a
large law firm, a midsized accounting firm, and a boutique tax law firm, Patrick’s
client exposures have covered every conceivable area of American-side
international tax matters. Patrick has also represented every type of taxpayer
– from multibillion-dollar business enterprises and ultra-high net worth
individuals to startups and individuals with complex questions but limited
budgets. Mr. McCormick has worked with clients located in over 90 countries on
American tax considerations of multinational activities, cultivating
specialized knowledge in every area of United States international tax rules.
Patrick's explicit practice focus has
facilitated an unparalleled expertise in the field; he is trusted by clients
and advisors around the world to obtain optimal results on international tax
matters.
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