Grant, Herrmann, Schwartz & Klinger LLP | David Sahargun | News & Publications
Established 1946
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Attorneys
David  M. Sahargun

PRACTICES

Wealth and Succession Planning
Tax Compliance
International Transactions
Tax Planning
Foreign Investment in US Real Estate
Shipping and Aviation
Art Law
Charities and Tax-Exempt Organizations

EDUCATION

  • American University, J.D.
  • Universidad Pontificia Comillas, Master en Derecho de la Empresa
  • University of California, Berkeley, B.A. (High Honors)

ADMISSIONS

New York
David M. Sahargun
Partner
CONTACT INFORMATION
Tel: (212) 682-1800
Fax: (212) 682-1850
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  • Single-Member Foreign-Owned LLC Reporting Obligations

    01/03/2018

    The United States Treasury Department and Internal Revenue Service (IRS) issued final regulations in December of 2016 that now subject foreign-owned single-member limited liability companies (LLCs) that are disregarded for U.S. income tax purposes (i.e., LLCs that have not elected to be classified as corporations) to the informational reporting requirements established under Internal Revenue Code (IRC) Section 6038A for 25% foreign-owned United States corporations. The new regulations now generally require foreign-owned single-member LLCs to obtain a U.S. employer identification number (EIN) and annually file a pro forma Form 1120 corporate income tax return together with Form 5472 identifying each 25% or greater direct and ultimate indirect foreign owner. The first filings pursuant to the new regulations will generally be due as early as April 17, 2018, covering tax years starting in 2017. The IRS will assess a penalty of $10,000 for each year the new reporting requirement is not timely satisfied.

  • FATCA Update: IRS Expands List of IGA Countries
    April 11, 2014

    Update by David M. Sahargun

  • Inversiones Inmobiliarias en EEUU
    January 2014

    Memorandum by David M. Sahargun

  • U.S. Tax Issues Affecting Mexican Clients
    November 12, 2013

    Presentation by David M. Sahargun