Form 8832: Employer Identification Number.

[The Real Halloween]

A foreign entity with a single owner having limited liability, electing to be an entity disregarded as an entity separate from its owner.

Does the newly incorporated foreign entity need to apply for EIN to complete Form 8832? Are you allowed to leave the EIN box blank on f8832?

Thanks for your time and comment.

[itonewbie]

Yes, EIN is needed.

[itonewbie]

You may have already thought through it.  Assuming this is a non-per se foreign entity, CTB election will certainly make the reporting much simpler.  However, it may not always be the best option and alternative to CTB election is available.

[The Real Halloween]

@itonewbie 

Thanks for your comments.

Please let me know what the CTB election is and the alternative to such election.

[itonewbie]

CTB is check-the-box election.

[The Real Halloween]

@itonewbie Thanks.

Can a single owner TP use foreign earned income exclusion (f2555) to exclude part of its Schedule C net income which is net income from foreign disregarded entity (CBT f8832 election)?

Thanks again for your time and comment

[itonewbie]

With or without CTB, your client should have income that is excludable if your client qualifies for §911.

[The Real Halloween]

@itonewbie Thanks.

Assuming client qualifies for §911 and claims FEIE on Sch C earnings, would the IRS challenge this FDE without CTB election? Does client need to file f8858 if he does not make CTB election and the FDE's earnings flow through Sch C?

Thanks for your time and comment.

[itonewbie]

The non-per se entity's default classification is a corporation separate from the taxpayer.  If your client wants to treat that as an FDE, timely CTB election must be made.  But that has nothing to do with your client's eligibility for §911.  You may have gotten the two mixed up.

[The Real Halloween]

@itonewbie Thanks alot!