Client Alert: Compliance with New Reporting Requirements for Foreign-Owned LLCs

The Internal Revenue Service (“IRS”) released final regulations that subject a U.S. single-member Limited Liability Company (“SMLLC”), wholly owned by a foreign individual or entity, to new reporting requirements for U.S. tax purposes. All foreign-owned U.S. SMLLCs in existence on or after December 13, 2017 will be subject to the new reporting requirements; however, if the existence of an SMLLC is terminated prior to December 13, 2017, it will not be subject to these new reporting requirements.