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Course Details

Understanding the Complexities of Form 5472 and Its Transfer Pricing Implications

Webinar: ID# 1015614
Recorded CD
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About This Course:
As more foreign companies view the U.S. market as a fertile market, they will form U.S. subsidiaries to grow their U.S. operations.

Whether you are the U.S. subsidiary for a large, Dutch-based multinational company with subsidiaries all over the world or a small U.S. distributor of a Canadian parent, you will have to file IRS Form 5472 for every transaction with a related party. Although an information return, the Form 5472 is the place the IRS starts when auditing foreign-owned U.S. businesses.

As a result, the proper preparation of the Form 5472 will offer an opportunity to document your planning as well as make that planning audit proof. In this webinar, you will learn the law behind and the mechanics of how to prepare Form 5472. The enforcement policies of the IRS with respect to failure to file Form 5472 will also be addressed.

Agenda:

Determining Who Is a Reporting Corporation for Part I
    Determining What Is a 25 Percent Foreign Shareholder for Part II
    Determining Who Is a Related Party for Part III
    Determining the Nature and Amount of Intercompany Transactions for Part IV
    A Primer on Transfer Pricing for Intercompany Transactions
      About The Presenter:

      Robert J. Misey, Jr.
      • Chair of the International Department of Reinhart Boerner Van Deuren s.c.
      • Listed in the Best Lawyers In America
      • Admitted to the State Bar of California, Kentucky Bar Association, State Bar of Wisconsin and The District of Columbia Bar
      • LL.M. degree, Geogetown University; J.D. and M.B.A. degrees, Vanderbilt University; B.A. degree, University of Kentucky
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      Understanding the Complexities of Form 5472 and Its Transfer Pricing Implications
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