tag:blogger.com,1999:blog-6398232680738279469.post5024790016881772462..comments2024-03-12T07:30:17.846-07:00Comments on The Tax Times: IRS Issues Final Regs on § 6038D Domestic Entities Reporting on Foreign Financial Asset Which Eliminate Principal Purpose TestRonald A. Marini, Esq.http://www.blogger.com/profile/14304486100168506240noreply@blogger.comBlogger1125tag:blogger.com,1999:blog-6398232680738279469.post-72680380387452875612016-05-09T12:03:57.569-07:002016-05-09T12:03:57.569-07:00For example, under the proposed regs, contribution...For example, under the proposed regs, contributions and distributions would be considered reportable transactions with respect to such entities. <br /><br />Accordingly, a transaction between such an entity and its foreign owner (or another disregarded entity of the same owner) would be considered a reportable transaction for purposes of the Code Sec. 6038A reporting and record maintenance requirements, even though, because it involves a disregarded entity, it generally wouldn't be considered a transaction for other purposes, such as making an adjustment under Code Sec. 482. (Prop Reg § 1.6038A-2(b)(9), Example 1)Ronald A. Marini, Esq.https://www.blogger.com/profile/14304486100168506240noreply@blogger.com