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In general, a foreign branch for U.S. tax purposes is a division which operates a trade or business in a foreign country and maintains a separate set of books and records. The foreign branch generally is subject to the income tax laws in the foreign country in which it operates.
The maximum foreign earned income exclusion amount is adjusted annually for inflation. For tax year 2023, the maximum foreign earned income exclusion is the lesser of the foreign income earned or $120,000 per qualifying person. For tax year 2024, the maximum exclusion is $126,500 per person.
The branch profits tax is imposed on foreign corporations engaged in the conduct of trade or business in the United States and is equal to 30% of the dividend equivalent amount for the tax year. This tax is in addition to the corporate-level tax imposed on taxable income effectively connected with that US business.
Any foreign corporation carrying on business in the U.S. without a PE must file Form 1120-F (U.S. Income Tax Return of a Foreign Corporation) to report income connected with the U.S. trade or business activity.
For Form 1120-S or Form 1120-F Attach to the amended Form 1120S/1120-F, the XML document, AmendedReturnChanges, that identifies the line number of each amended item, description, the amount on the previous return, the amount on the amended return, and an explanation of the reasons for each change.

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A foreign corporation is an existing corporation that is registered to business in a jurisdiction (such as a foreign country) other than the one where it was originally incorporated.
Foreign-owned LLCs are generally treated as pass-through entities for federal tax purposes. This means that the LLC itself does not pay federal income taxes. Instead, the profits and losses of the LLC pass through to the individual members, who report them on their personal tax returns.

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