Get Regulation 103735-00 - Modification Of Tax Shelter Rules II. Temporary And Proposed Regulations

While there are plenty of completely legitimate and credible forms of tax shelters, many individuals and tax scammers use tax shelters to illegally lower their tax liability. Any tax shelter that is used solely for the purpose of lowering tax liability is considered abusive.

A foreign person means someone who is not either a citizen of the U.S. or a lawful alien possessing a valid I-551. What is a foreign entity?

A non-citizen is, in most cases, subject to U.S. tax on income from U.S. sources. Form 1042-S, Foreign Person's U.S. Source Income Subject to Withholding, is used to report amounts paid to foreign persons (including those presumed to be foreign) by a United States based institution or business.

A Foreign Person is a nonresident alien individual or foreign corporation that has not made an election under section 897(i) of the Internal Revenue Code to be treated as a domestic corporation, foreign partnership, foreign trust, or foreign estate. It does not include a resident alien individual.

Foreign partnerships. A foreign partnership is any partnership (including an entity classified as a partnership) that is not organized under the laws of any state of the United States or the District of Columbia or any partnership that is treated as foreign under the income tax regulations.

A foreign person includes a nonresident alien individual, foreign corporation, foreign partnership, foreign trust, foreign estate, and any other person that is not a U.S. person.