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Where Taxpayers and Advisers Meet

US Tax classification on UK Limited Company

jack1980
Posts:1
Joined:Tue Sep 04, 2018 1:39 pm
US Tax classification on UK Limited Company

Postby jack1980 » Tue Sep 04, 2018 1:51 pm

Good afternoon everyone,

I am thinking of closing my current UK company as it is treated as a corporation in the US (silly me!). Since I will be paying myself wages/dividends in the coming months there should be no undistributed earnings this year which will help to avoid paying GILTI. Small victories!

Instead of possibly closing the company, I am wondering if it wouldn't make more since to just make an 8832 election for the current company to be treated as a partnership? Since my old company will no longer have any assets or reserves once I pay wages/dividends in the coming months, would that simply make more sense? As anyone here done such a change of classification? Any tax issues I am not seeing?

Thanks a lot

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