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Where Taxpayers and Advisers Meet

Completion of IRS form 8833

Jane Ascroft
Posts: 1
Joined: Thu Dec 13, 2018 2:02 pm

Completion of IRS form 8833

Postby Jane Ascroft » Thu Dec 13, 2018 2:08 pm

I am completing an IRS form 8833 for a UK company client of mine with US business income but no permanent establishment in the US. Straight forward application of the UK-US tax treaty. I am struggling with the question 2 that asks "List the Internal Revenue Code provision overruled or modified by the Treaty Based Return provision". Any help would be appreciated! The rest of the form is fine, as is the 1120-F form.

DavidTreitel
Posts: 195
Joined: Thu Aug 16, 2012 4:31 pm

Re: Completion of IRS form 8833

Postby DavidTreitel » Sat Dec 15, 2018 1:50 pm

Jane - just a helpful hint. You doubtless have a PTIN (so that you can sign as preparer to avoid the IRS preparer penalty). You are hopefully also qualified in the States (as an EA or CPA). From a practical perspective, however, as you are located in the UK you will want to double check with your PII insurer that you are insured to prepare US tax returns for your client.

In terms of tax, as you are preparing an 1120-F, is this a protective 1120-F? Did the company directors have any US workdays? If so, are you also preparing their individual US tax returns (Form 1040NR) and ITIN applications (Form W-7)? Happy to act as an IRS Certifying Acceptance Agent for ITIN applications if needed.


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