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Mastering Form 5472: New Filing Requirements For Foreign Individuals, LLCs, And Companies

Webinar: ID# 1026129
Recorded CD
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About This Course:
This webinar will provide tax advisers with a thorough and practical guide to completing Form 5472, focusing on the impact of new IRS regulations requiring 5472 reporting by foreign owners of disregarded entities (DREs). The panel will provide line-by-line guidance to completing the form, defining key concepts and discussing the impact of recent IRS rules expanding filing requirements.

Form 5472, “Information Return of a 25% Foreign-Owned U.S. Corporation or a Foreign Corporation Engaged in a U.S. Trade or Business,” is one of the most complicated forms applicable to foreign companies. Originally, the reporting obligations applied to corporations only; however, IRS announced changes in 2016 that extends the reach of Form 5472 requirements to non-U.S. individuals owning DREs active in the U.S.

IRC 6038 requires “reporting corporations” to disclose specified “reportable transactions” they have with any “related parties” on Form 5472. The definition of each element is highly complex, and tax advisers must have a thorough grasp of these definitions to ensure that the taxpayer has met the record maintenance requirements to support its tax position for these transactions.

In Dec. 2016, Treasury regulations expanded the scope of the filing requirements. In response to foreign individuals’ use of DREs to avoid information reporting, the Service now requires foreign-owned single member LLCs and other DREs to file Form 5472. Foreign persons who own a single-member domestic DRE, either directly or indirectly through attribution rules, must obtain an taxpayer identification number and disclose reportable transactions. Penalties for failing to file Form 5472 may reach $10,000 per failure, with complicated rules for penalty mitigation.

Listen as our experienced panel provides a thorough and practical guide to completing Form 5472, including key definitions and a discussion of the expanded filing requirements.

Outline
  • Statutory provisions of IRC 6038A and 6038C
  • Key definitions
    • Reporting corporations
    • Reportable transactions
    • Related parties
  • New regulations (TD 9796) requiring foreign-owned DREs to file Form 5472
  • Completing the form
  • Penalty abatement provisions
Benefits

The panel will discuss these and other important issues:
  • What entities and individuals are subject to Form 5472 filing requirements?
  • Identifying key elements of IRC 6038A and 6038C to determine definitions of transactions that must be reported
  • Line-by-line guidance on completing Form 5472
  • Steps that foreign individuals owning DREs operating in the U.S. must take to fulfill filing requirements
  • Penalty abatement and mitigation provisions
Learning Objectives

After completing this course, you will be able to:
  • Identify key elements of IRC 6038A and 6038C to determine reportable transactions.
  • Establish which entities must file Form 5472.
  • Recognize reportable transactions with related parties that must be reported on Form 5472.
  • Determine the new regulations impact on disregarded entities and whether a disregarded entity will be treated as a corporation for Form 5472 filing purposes
  • Ascertain applicable penalties for failure to file Form 5472 or to maintain records.
  • Discern available exemptions and penalty abatement provisions for failure to file Form 5472 or maintain records.
Course And Materials

Handout materials and the phone number for live presentations are made available to you one day prior to the event via email from the presenter. Copies of the presentations are included with recorded versions.

If you order a recorded version of the webinar, CDs will be mailed out approximately 10 days after the live event. Shipping is included in the price of recorded versions.

Continuing Education Credits Available

This program has been approved for 2.0 CPE hours through Strafford Publications. To obtain CPE credit, attendees must participate in the live event (recorded versions do not qualify for credit), return an Official Record of Attendance to Strafford affirming their participation (including the CPE code announced during the program), and pay a processing fee of $35 per person.

Strafford will mail a certificate of credit within approximately two weeks of receiving your completed Official Record of Attendance, provided all required conditions have been satisfied.

Strafford is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit.
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Mastering Form 5472: New Filing Requirements For Foreign Individuals, LLCs, And Companies
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