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Course/Product Description
Title:

IRS Form 5471: Information Return For U.S. Persons With Respect To Certain Foreign Corporations

SKU:WC-1023863
Date / Time: Recorded
Format: Webinar
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Description:

United States persons who own interests in foreign entities must comply with a variety of U.S. reporting requirements. One of the most common, and also most complex, is the Form 5471 requirement.

Most tax practitioners know that U.S. shareholders of controlled foreign corporations must file a Form 5471. But the reporting requirement applies to a variety of other U.S. persons-including, in some cases, U.S. persons who are not direct shareholders of a foreign corporation.

Completing the Form 5471 can be a daunting task. Shareholders frequently must report detailed information regarding the corporation's assets and income and significant penalties may apply to taxpayers who fail to comply with the Form 5471 reporting requirement.

AGENDA

Who Must File?

  • Category 2 Filers - U.S. Officers or Directors of Certain Foreign Corporations
  • Category 3 Filers – Transactional Filing Requirement for U.S. Persons
  • Other Considerations:
  • Category 4 Filers - U.S. Persons Who Control a Foreign Corporation
  • Attribution Rules
  • Category 5 Filers – U.S. Shareholders of CFCs
  • CFC Defined
  • U.S. Shareholders of a CFC Defined
  • Other Considerations for U.S. Shareholders
Completing Form 5471
  • Content for Category 2 – 5 Filers
  • Common Mistakes and Red Flags
Penalties for Failure to File
  • Monetary Penalty
  • Loss of Foreign Tax Credits
  • Extension of Statue of Limitations
Resolving Noncompliance
  • Delinquent Information Return Procedure
  • Requirements
  • Penalties
  • Offshore Voluntary Disclosure Program
  • Requirements
  • Penalties
  • Streamlined Procedure
  • What Constitutes "Reasonable Cause" and Non-Willful Conduct?
About The Presenters

Kevin Hall
  • Tax lawyer at Holland & Knight LLP
  • Practice focuses on domestic and international taxation; includes tax advice to clients on a wide range of transactions, and to foreign clients investing in the United States and to U.S. clients investing internationally
  • Writes and speaks about international tax topics
  • Admitted to the Florida and D.C. Bar and is a certified public accountant in Florida
  • J.D. degree, University of Florida Levin College of Law; M.S. degree in accounting, and B.S. degree in business, Wake Forest University; LL.M. degree in taxation, New York University School of Law
Natalia Velez
  • International Tax senior manager at RSM US LLP
  • Provides international tax advisory services to businesses and individuals, including inbound and outbound transaction planning focusing primarily on structuring client’s international operations to minimize their worldwide effective tax rate
  • Analyzes the impact of recent tax legislation and income tax treaties on cross-border transactions, including permanent establishment and tax residence thresholds, as well as applicable taxes
  • Complex reporting of foreign financial assets and extensive offshore voluntary disclosure experience
  • Pre-immigration and expatriation tax planning and compliance
  • Master’s degree in taxation, Boston University


Cannot Attend The Live Presentation?

This presentation is also available in a recorded format, in CD version, as shown in the pricing options below.

About Webcasts / Audio Conferences / Podcasts:

Webcasts, audio conferences, and podcasts are presentations that you attend via the Internet, phone, or mobile device at a specified date and time for "live" versions, or at your convenience for "recorded" and "On-Demand" versions.

The live versions are interactive, meaning that participants can ask questions in real time, plus are a very cost-effective form of training because 1) you receive fast, convenient learning without any out-of-office time; 2) you can invite as many colleagues as you'd like to listen in on a single phone line; 3) you incur no travel expenses; and 4) you and your colleagues are back at work immediately after the session ends!

And though with recorded versions you do lose the ability to ask questions, you gain the ability to hear the presentation numerous times and to share it with others in your office.

Handout materials and the phone number for live presentations are made available to you prior to the event via email from the presenter and from the "MyAccount" link on the menu bar. Copies of the presentations are included with recorded versions.

About The Provider: Lorman Education Services has provided educational seminars and online training for professionals since 1987.

Since then, we've kept thousands of professionals in the United States and internationally current on the most pressing topics in a rapidly changing marketplace of ideas. Like you, we understand the need for concise, accurate information.

That understanding underlies each Lorman course, presenting the latest information on the laws and regulations critical to your organization's successful daily operations.

Moreover, each course receives our painstaking attention to be certain both the faculty and participants receive the individual attention necessary to achieve maximum benefit from the materials.
More Info: Contact Us For More Information
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