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In this example FDE 1 is the direct owner of FDE 2 and CFP is owner with respect to both FDE 1 and FDE 2. Special rules for DASTM. If the FDE uses DASTM the functional currency column should reflect local computed in accordance with U.S. GAAP. A would be required to file the Forms 8858 relating to FDE 1 and FDE 2 with the Form 8865 it files with respect to CFP. If you are completing Schedule M Form 8858 for an FDE for which the tax owner is a CFC check the box for CFCs and complete lines 1...
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Who needs instructions for form 8858?

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Individuals who are required to report information about certain foreign-owned businesses
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Taxpayers who have ownership or control of a foreign disregarded entity
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Those with certain transactions with foreign corporations or partnerships
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Owners of Controlled Foreign Corporations (CFCs)
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Taxpayers with foreign branches, foreign tax-favored entities, or foreign partnerships
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Form 8858 is used by U.S. persons that are shareholders in certain foreign corporations to report information about the foreign corporation.
U.S. persons who are shareholders in certain foreign corporations are required to file Form 8858.
Instructions for filling out Form 8858 can be found on the official IRS website or in the instructions provided along with the form.
The purpose of Form 8858 is to report information about foreign corporations in which U.S. persons are shareholders.
Information such as the name and address of the foreign corporation, the nature of the shareholder's interest, and financial information of the foreign corporation must be reported on Form 8858.
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