EFTA02667901

From: jeffrey E. <[email protected]> Sent: Tuesday, November 29, 2016 10:38 PM To: Jeffrey Epstein &quo=;u.s. shareholders" of a CFC are required to file Form 5471 with thei= personal tax return, even if the CFC has no subpart F income. Form 926 is used to report transfers ofproperty (including cash) to a foreign corporation. Si nc= a foreign corporation will have some kind of foreign bank or financial accoun=, the U.S. shareholders who have control, signatory authority or a financial interest, over the account must file Form TD F 90-22.1 by June 30th of the =ear after the calendar year. If the foreign corporation's shareholders have=made an election to have the corporation treated as a disregarded (non-corporate)en=ity for U.S. tax purposes, then the shareholders must file a Form 8865 for a foreign partnership and a Form 8858 for a foreign disregarded entity. In or=er to make an election to be treated as a disregarded entity, a Form 8832 must=be filed. If the foreign corporation has made an investment in any passive for=ign investment companies, or if the foreign corporation is a PFIC, then the U.S= shareholders may be required to file a Form 8621 to report their share of t=e income of the PFIC or the gain on any dispositions of PFIC shares. If the Foreign Corporation has any U.S.-source income, it will need to file a Form 1120-F. If it is a Foreign Sales Corporation, it will need to file a Form 1=20-FSC. In the event of the purchase or sale of a foreign corporation, the buyer an= seller will need to file a Form 8883, which is an Asset Allocation Statemen=. If the shareholders or the corporation rely on a treaty that overrides a provi=ion of the IRC, a Form 8833 must be filed to reflect a Treaty Based Return Posi=ion. Depending on the nature of thebusiness of the corporation, other forms may be required please note The inform=tion contained in this communication is confidential, may be attorney-c=ient privileged, may constitute inside information, and is intended onl= for the use of the addressee. It is the property of JEE Unauthor=zed use, disclosure or copying of this communication or any part thereo= is strictly prohibited and may be unlawful. If you have received thisc=r>communication in error, please notify us immediately by return e-mail=or by e-mail to <mailto:[email protected]> , and destroy this communication and all copier thereof, including all attachments. copyright -all rights reserved =/div> EFTA_R1_01919814 EFTA02667901