Tag: I.R.C. § 882(c)(2)

17
Feb

The Tax Court Reminds Foreign Corporations of the Disastrous Consequences of Failing to File Forms 1120-F U.S. Income Tax Returns

By: Heather L. Marello, Esq. I.R.C. § 6012(a)(2) imposes an income tax return filing requirement on “every corporation subject to taxation under subtitle A.”  The Treasury Regulations clarify that a foreign corporation is not exempt from U.S. taxation if it is engaged in a U.S. trade or business, even if it has no effectively connected U.S. income or its income

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