11-12-2010, 04:41 AM
Hello,
I have C Corp "AB" (51% USA CA resident and 49% Russia resident). "AB" owes 49% of "CD" Corp, which is based in Russia. The Russia resident will promote product of "CD". In return "CD" could pay Dividend or commissions.
1.Can I take 80% Dividend exclusion when I file "AB" USA tax return? 2.Would it be better if "CD" pays commissions versus Div? 3. When "AB" pays dividend, then I will have to file 1040NR for Russia resident? 4. Are there any other reporting requirements? 5. Would it be better to form LLC versus C corp? 6.If I form LLC, who will be the subject to self-employment tax? The USA resident, who will be a passive partner in realty or Russia resident but he is not living in the USA so he will not be subject to SE tax.
Please help, totally lost
I have C Corp "AB" (51% USA CA resident and 49% Russia resident). "AB" owes 49% of "CD" Corp, which is based in Russia. The Russia resident will promote product of "CD". In return "CD" could pay Dividend or commissions.
1.Can I take 80% Dividend exclusion when I file "AB" USA tax return? 2.Would it be better if "CD" pays commissions versus Div? 3. When "AB" pays dividend, then I will have to file 1040NR for Russia resident? 4. Are there any other reporting requirements? 5. Would it be better to form LLC versus C corp? 6.If I form LLC, who will be the subject to self-employment tax? The USA resident, who will be a passive partner in realty or Russia resident but he is not living in the USA so he will not be subject to SE tax.
Please help, totally lost