Foreign Bank Accounts
- Account Holder information, including birth date
- Bank Name
- Bank Address
- Account Number
- Type of Account
- Maximum Value, measured on a month-end basis
- Joint Holder information, if applicable
- Businesses: signatory information, including title
Passive Foreign Investment Companies (PFICs)
- Name, Address, EIN and Tax Year of PFIC or QEF
- Annual PFIC Statement
- If no PFIC Statement, amount of distributions in current year from fund and amount of distributions in each of the prior three years from fund.
- If no PFIC Statement, date and amount of proceeds for dispositions in current year, date of original purchase and cost of shares sold.
Foreign Corporations Doing Business in the U.S.
- Name, Address, EIN (if any)
- Ownership Structure, including tax residence of owners
- Business Activity in the US (DETAILS)
- Financial Statements
- Related Party Transactions
- Treaty Positions
Foreign Subsidiaries Of U.S. Businesses
- Name, Address, EIN (if any)
- Date of Incorporation
- Place of Business and Business Activity
- Functional Currency
- Agents / Custody of Books in foreign country, if not subsidiary
- Ownership: shares, (by type and by owner), identifying information of owners
- Income Statement
- Balance Sheet
- Earnings & Profits Adjustments
- Related Party Transactions
- Details regarding ownership changes
Foreign-Owned U.S. Corporations
- Ownership Structure (all > 25% direct and indirect owners)
- Related Party Transactions
Foreign Partnerships
- Name, Address, EIN (if any)
- Date of Organization
- Place of Business and Business Activity
- Functional Currency and Exchange Rate
- Agents / Custody of Books in foreign country, if not partnership
- Name, Address EIN/SSN of other partners
- Income Statement
- Balance Sheet
- Book/Tax Income Reconciliation (Schedule M-1)
- Analysis of Partners’ Capital Accounts (Schedule M-2)
- Capital Gains/Losses detail
- Partner Allocations
- Related Party Transactions
Foreign Disregarded Entities
- Name, Address, EIN (if any)
- Date of Organization, including effective date as disregarded
- Place of Business and Business Activity
- Functional Currency and Exchange Rate
- Agents / Custody of Books in foreign country, if not partnership
- Tax owner of foreign entity, if not US Tax Filer
- Direct owner of foreign entity, if not tax owner or US Tax Filer
- Summary Income Statement
- Summary Balance Sheet
- Earnings & Profits Adjustments
Transfers of Property to Foreign Corporations
- Details regarding Structure/Ownership before and after the transfer
- Name, Address, EIN (if any) of Transferee Corporation
- Country of Incorporation of Organization
- Characterization of Corporation under foreign law
- Status as CFC
- Transfer, Date, Description, FMV, Cost Basis, Gain Recognized
- IRC Code Section(s) governing the transaction
Information Gathering Checklist
- Foreign Bank Accounts
- Passive Foreign Investment Companies (PFICs)
- Foreign Corporations Doing Business in the U.S.
- Foreign Subsidiaries of U.S. Businesses
- Foreign-Owned U.S. Corporations
- Foreign Partnerships
- Foreign Disregarded Entities
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