Miami Gardens Florida Form 5471 (Schedule O) 2012-2025

Miami Gardens Florida Form 5471 (Schedule O): What You Should Know

Form 5471 for Foreign Firms — IRS 25 Oct 2025 — Schedule O of Form 5471 contains the organization or reorganization from which shares were acquired under Section 83(c)(5) of the IRC. Treasury Regulation Section 83(c)(5)(A) The corporation has been acquired when, as of the earliest of: (1) the date of acquisition of the shares, (2) the date of the registration under the Code of the disposition of the shares, (3) the date of the disposition of the shares, or (4) the date of filing of the registration statement by the transferor of the shares which included the notice required under Section 83(g) of the IRC that the shares of which were acquired or acquired and sold by each person are subject to tax under this Act. Treasury Regulation Section 83(c)(5)(B) A transfer of shares of stock of a domestic corporation is not an acquisition of or a disposition of the stock unless there is actual receipt of the stock by a U.S. shareholder or a person holding foreign stock. Treasury Regulation Section 83(c)(5)(C) A subsequent acquisition of shares that are treated as part of a transaction that is an acquisition of or a disposition of stock, is a transaction involving an acquisition of or a disposition of the stock. The following rules govern: (i) For purposes of this part, only purchases of the transferred stock are considered acquisitions; and (ii) Acquisition, in the case of an exchange, is defined as the actual receipt of the stock by the transferor by mail or other recorded means. The transaction includes any portion of the stock of an acquisition of stock effected in the ordinary course of the business of the acquiring corporation. The following are examples of transactions that are not acquisitions as defined in IRC Section 83(c)(5):  Stock purchased by the U.S. shareholder in a sale of that U.S. shareholder's stock. Receipt of the stock by the transferor of the shares to which the stock was transferred.

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