Page 67 - International Taxation IRS Training Guides

Individual Foreign Pass-Through Entities

 A U.S. individual who conducts activities or

investments through a foreign pass-through entity will

be generally subject to U.S. tax on all income earned
through the entity on a current basis.

 An individual
may make that investment through a

foreign pass-through entity such as:
• A foreign partnership

• A foreign disregarded entity or foreign branch

• A foreign trust

 Each pass-through entity will
differ in how U.S. tax is

imposed.

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