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Get the free 2008 Form 1120-F (Schedule P) - IRS - irs

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SCHEDULE P (Form 1120-F) Department of the Treasury Internal Revenue Service List of Foreign Partner Interests in Partnerships Attach to Form 1120-F. See separate instructions. OMB No. 1545-0126 2008
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See also Section 961(b)(2)(A) and paragraph (a) of this section. Listed (1) Trade or business (2) Person with direct or indirect business interests (3) Company(s) A company is a U.S. trade or business only if it is a corporation or for-profit partnership, and (1) It directly, through a U.S. person, or indirectly, by a series or series(s) of U.S. persons, directly or indirectly owns, directly or indirectly, 30 percent or more of the ownership interests in any entity that has one of the 10 types of partners in a partnership or association with at least one person other than the U.S. person in the year, or (2) It is a partnership and, at all times during the taxable year, one or more individuals, including a domestic corporation, who is neither an individual nor a partnership member, and who is neither a United States person nor a resident alien, controls, or at all times during the taxable year materially participates in the management of any U.S. trade or business and that is not owned, controlled, or controlled by a foreign person. A foreign person is a foreign corporation, or controlled foreign corporation, at any time if (1) It is established and is actively engaged in a trade or business in, or is carrying on a business or operations in, the United States; (2) It is not substantially owned by a United States person; and (3) It is not controlled by United States persons. For purposes of this exception, foreign persons include a corporation or controlled foreign corporation that is a partnership. Note: A business may be a trade or business only if it is carried on from one country into another. An international financial institution (IFI) is a business if it is a U.S. company that is not a foreign corporation, trusts, or estates that are treated as foreign corporations under section 901(a). An IFI that carries on business in the United States is a U.S. trade or business.

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