Foreign corporations engaged in business in the United States must comply with particular record-keeping and international tax reporting obligations under the Internal Revenue Code. The code sections pertaining to foreign-owned domestic corporations and businesses also apply to U.S. taxpayers who engage in business with these companies. These rules are enumerated under IRC §§ 6038A and 6038C, which were enacted in the 1980s and later strengthened and expanded throughout the 1990s.

Reporting Obligations Prior to IRC § 6038

Prior to the enactment of IRC §6038A, U.S. parent corporations were required to report transactions that occurred between the corporation and its foreign affiliates and between Read More