What are the tax consequences if my S corporation earns money in a foreign country?
"Be careful here: If ACME were in California, I would pay taxes on USD 17,000 because I   had revenue of 20,000 and expenses of 3,000. To CALIFORNIA. And California taxes S-Corps. And, in addition, you'd pay $800 for the right of doing business in the State. All that in addition to the regular Federal and State taxes to the State where you're resident. Suppose that ACME is in Britain (or anywhere else for that matter). My   revenue and expenses are the same, but now my money has been earned   and my expenses incurred in a foreign country. Same thing exactly. Except that you'll have to pay taxes to the UK. There may be some provision in the tax treaty to help you though, so you may end up paying less taxes when working in the UK than in California. Check with a licensed tax adviser (EA/CPA licensed in your State) who won't run away from you after you say the words ""Tax Treaty"". Does it even make sense to use my S-Corporation to do business in a   foreign country? That should be a business decision, don't let the tax considerations drive your business."
If you hold this money in USD and spend it in the US as USD, then there is no tax liability or reporting requirement at all.  You are not subject to any tax on foreign exchange gains and losses because you have not performed any foreign exchange.  CRA says a foreign exchange gain or loss happens when the fx transaction occurs—not as the currency’s value fluctuates while on deposit - and since you are never performing an fx transaction, no such issues will arise.  The CRA is not interested in how you spend your money, only the money that you earn.   The only possible tax liability that would arise in the circumstances that you describe would be the tax liability arising from interest earned while the cash in on deposit.  If this interest exceeds the threshold of reportability, then your bank will issue you with a T-slip to be included in your tax return. "Answers: 1: No, Sections 1291-1298 of the IRC were passed in the Reagan adminstration. 2: Not only can a foreign company like a chocolate company fall afoul of the definition of PFIC because of the ""asset test"", which you cite, but it can also be called a PFIC because of the ""income test"".  For example, I have shares in a development-stage Canadian biotech which is considered a PFIC because it has no income at all, except for a minor amount of bank interest on its working capital.  This company is by no means ""passive"" (it has run 31 clinical trials in over 1100 human research subjects, burning $250M of investor's money in the process) nor is it an ""investment company"", but the stupid IRS considers it to be a ""passive foreign investment company""!  The IRS looks at it and sees only the bank account, and assumes it is a foreign shell corporation set up to shield the bank interest from them. 3: Yes, a foreign mutual fund is EXACTLY what congress intended to be a PFIC when passed IRC 1291-1298.  (Biotechs, candy factories, ect got nailed as innocent bystanders.)  Note that if you hold a US mutual fund then every year you'll get a form 1099 in the mail.  The 1099 will report your share of the mutual fund's own income and capital gains, which you must report on your taxes.  (You can also have capital gains from selling your shares of the mutual fund, but that's a different thing.) Now suppose that there was no PFIC law.  Then the US investors in the mutual fund would do better if the mutual fund were in a foreign country, for two reasons: a) The fund would no longer distribute 1099's.  That means the shareholders wouldn't have to pay tax every year on their proportions of the fund's own income/gains.  The money that would have sooner gone to the IRS can sit around for years earning interest. b) The fund could return profits to shareholders exclusively through capital gains rather than dividends, thus ensuring that all of the investors' income on the fund would be taxed at <15%-20% rather than up to 39%.  The fund could do this by returning cash to shareholders exclusively through buybacks. However, the US mutual fund industry doesn't want to move the industry to Canada, and it only takes a few newspaper articles about a foreign loophole to make congress spring to action. 4) It depends.  If you have a PEDIGREED QEF election in place (as I do for my biotech shares) then form 8621 takes a few minutes by hand.  However, this requires both the company and the investor to fully cooperate with congress's vision for PFICs.  The company cooperates by providing a so-called ""PFIC annual information sheet"", which replaces the 1099 form for a US mutual fund.  The investor cooperates by having a ""QEF election"" in place for EACH AND EVERY TAX YEAR in which he held the stock and by reporting the numbers from the PFIC annual information sheet on his return.  (Note that the QEF election persists once made, until revoked.  There are subtleties here that I am glossing over, since ""deemed sale"" elections and other means may be used to modify a share's holding period to come into compliance.) Note that there is software coming out to handle PFICs, and that the software makers will already run their software to make your form 8621 for $75 or so.  I should also warn you that the blogs of tax accountants and tax lawyers all contradict each other on the basic issue of whether you can take capital losses on PFICs for which you have no form 8621 elections.  (See section 2.3 of my notes http://tinyurl.com/mh9vlnr for commentary on this mess.)  I do not know if the software people will tell you which elections are best made on form 8621, though, or advise you if it's time to simply dump your investment. The professional software is at 8621.com, and the individual 8621 preparation is at http://expattaxtools.com/?page_id=242. BTW, in case you're interested, I wrote up a very careful analysis of how to deal with the PFIC situation for the small biotech I invested in in certain cases. It is posted http://tinyurl.com/mh9vlnr.  (For tax reasons it was quite fortunate that the share price dipped to near an all-time low on Jan 1, 2015, making the (next) 2015 tax year ripe for a so-called ""deemed sale"" election.  This was only possible because the company provides the necessary ""PFIC annual information statements"", which your chocolate factory may or may not do.)" I assume that you are a citizen of India, and are what Indian law calls a NRI (NonResident Indian) and thus entitled to operate an NRE (NonResident External) account in India.  You can deposit US dollars into the NRE account, but the money is converted to Indian Rupees (INR) and held as INR.  You can withdraw the money and bring it back to the US as US dollars, but the INR will be converted to US$ at the exchange rate applicable on the date of the transaction.  With the recent decline of the Indian Rupee against the US dollar, many NRE accounts lost a lot of their value. You can deposit any amount of money in your NRE account. Some banks may limit the amount you can send in one business day, but if 250 times that amount seriously limits the amount of money you want to send each year, you should not be asking here; there are enough expensive lawyers, bankers and tax advisors who will gladly guide you to a satisfactory solution. There is no limitation on the total amount that you can have in your NRE account.  The earnings (interest paid) on the sum in your NRE account is not taxable income to you in India but you may still need to file an income tax return in India to get a refund of the tax withheld by the bank (TDS) and sent to the tax authorities. The bank should not withhold tax on the earnings in an NRE account but it did happen to me (in the past).  While the interest paid on your NRE account is not taxable in India, it is taxable income to you on your US tax returns (both Federal and State) and you must declare it on your tax return(s) even though the bank will not issue a 1099-INT form to you. Be aware also about  the reporting requirements for foreign accounts (FBAR, TD F90-22.1 etc). Lots of people ignored this requirement in the past, but are more diligent these days after the IRS got a truckload of information about accounts in foreign banks and went after people charging them big penalties for not filing these forms for ever so many years. There was a huge  ruckus in the Indian communities in the US about how the IRS was unfairly targeting simple folks instead of auditing the rich! But, if the total value of the accounts did not exceed $10K at any time of the year, these forms do not need to be filed. It seems, though, that you will not fall under this exemption since you are planning on having considerably larger sums in your NRE account. So be sure and follow the rules. &gt;So if some 3rd world country with 0 infrastructure offers a better tax environment, we should just join them in the race to the bottom?  US companies don't want to domicile in a 3rd world country. That's not who we compete with for corporate domiciling. We compete with other anglophone countries and some northern European countries with far lower tax rates.  &gt;but whatever is happening in the tax code that makes these inversions possible needs to be fixed.  That would be the high tax rate. Unless you want to make it illegal for an American company to buy another company or to sell itself. I expect we will hear that soon from some of the totalitarian leftists.  the NYTimes has the cyclical average effective corp tax rate for S&amp;P500 companies at 29%. That's pulled from CapIQ which pulls directly from SEC documents.  http://www.nytimes.com/interactive/2013/05/25/sunday-review/corporate-taxes.html  Citizens for Tax Justice is a hopelessly distorted propaganda outfit. The summary (let alone the org's name) should have alerted you that any findings are distorted bullshit.  These dumb fucks don't think stock compensation is an expense. They do not understand the economic reasoning behind accelerated depreciation. They are financially and economically retarded. On top of that they desire the full 35% corporate tax rate on all global income of US corporations without any deferments, by far the most punitive corporate tax treatment in the entire world. Here is the solution: any money made inside the United States will be taxed under US tax law.  You want to do business here, open up a US headquarters that handles all the sales tracking and reporting. No tax dollars, no operations inside the US.   The united states carries such bulk buying power that companies will be forced to abide by its rules. Let me restate question for clarity. Facts: Question: Are there any taxes for this transaction? Answer: (Added improvements provided by Eric) Generally No. Generally, it is not considered income until you sell and the sale price is greater than the purchase price. But with currency differences, there is an additional complication, section 988 rules apply. It could result in ordinary income or loss. Under Income Tax Act, tax liability depends on residency as defined under section 6 of the Income Tax Act, and not on citizenship. If you are resident in India, then your global income is taxable. As it appears from your question, you are not resident of India (182 days stay in India in a FY), as such you will have absolutely no tax liability for whatever income you earn outside India. Does my prior answer here to a slightly different question help at all? Are there capital gains taxes or dividend taxes if I invest in the U.S. stock market from outside of the country?