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Course Details

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

Webinar: ID# 1023863
Recorded CD
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About This Course:
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
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IRS Form 5471: Information Return For U.S. Persons With Respect To Certain Foreign Corporations
Available on CD format
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