International Aspects of Mitt Romney’s 2010 Tax Return
Mitt Romney’s 2010 tax return had a number of international related items. First, he has an interest in, or signature authority over, one or more financial accounts in Switzerland. See Question 7 on Schedule B. Presumably, he also filed an FBAR for the Swiss account(s).
Second, he had passive gross foreign source income of $1,525,982, with current year foreign income taxes paid on this income of $67,173. He also had $81,461 of a carryforward of passive foreign taxes from prior years, and he will carry forward $18,397 of passive foreign tax credits to 2011. He had an alternative minimum tax credit in the passive basket of of $77,565. See Forms 1116.
Although he had no general category foreign source income for 2010, he paid $690 of foreign taxes in the general category for 2010, and he carried forward $100,010 of foreign tax credits in the general category to 2010. His carry forward of general category foreign tax credits to 2011 will be $100,700.
Third, he filed Forms 8621 for seventeen passive foreign investment companies (“PFICs”). Four of these forms he made mark-to-market elections. Ten of the forms made qualified electing fund (“QEF”) elections. For one of the forms he appears to have made a QEF election in a prior year. Lastly, two of the forms related to Code §1291 funds.
Fourth, he filed a Form 8865 to reflect that he had contributed $172,109 to a Cayman Islands limited partnership.
Fifth, he filed Form 5471 to disclose his wholly owned Bermuda investment holding company. The company had a nominal deficit in current earnings during 2010 and reflected previously taxed income from prior Subpart F Income inclusions of $13,366.
Sixth, he filed two Forms 926 to disclose cash contributions to two Irish corporations. One of the transfers was for $1,523,419 and the other was for $139,625. Both contributions were non-taxable Code §351 exchanges.