Determining U.S. Shareholder and CFC Status
Defining U.S. Shareholders and CFCs; Direct, Indirect and Constructive Ownership; Form 5471 Categories
Note: CLE credit is not offered on this program
A live 110-minute CPE webinar with interactive Q&A
This webinar will analyze the rules for determining U.S. shareholder and controlled foreign corporation (CFC) status, including determining direct, indirect, and constructive ownership. Our panel of knowledgeable global tax veterans will provide real world examples that walk international practitioners through these complex determinations.
Outline
- Determining U.S. shareholder and CFC status: introduction
- U.S. person
- U.S. shareholder
- CFCs
- Attribution rules
- Direct ownership
- Indirect ownership
- Constructive ownership
- Safe harbor relief
- Form 5471
Benefits
The panel will cover these and other critical issues:
- Which categories of Form 5471 filers apply based on CFC status
- Common misunderstandings that lead to incorrect CFC classifications
- Attribution rules and ownership thresholds for U.S. shareholders
- Real life examples clarifying the complexities of CFC status determinations
Faculty

Patrick J. McCormick, J.D., LL.M.
Partner
Rimon Law
Mr. McCormick specializes in the areas of international taxation and multinational trusts and estates. He has... | Read More
Mr. McCormick specializes in the areas of international taxation and multinational trusts and estates. He has published assorted national articles and given innumerous national and local presentations on assorted areas of international tax. He is licensed to practice in the State of New Jersey and the Commonwealth of Pennsylvania.
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Laura M. Tshilumba, CPA
International Tax Expert and CPE Instructor
Ms. Tshilumba, CPA, is an international tax expert and CPE instructor with over 20 years of experience in public... | Read More
Ms. Tshilumba, CPA, is an international tax expert and CPE instructor with over 20 years of experience in public accounting and industry. Her multifaceted experience spans across various industries, giving her a profound understanding of the unique tax challenges faced by businesses and individuals. Whether working with multinational corporations, expatriates, solo entrepreneurs, or high-net-worth individuals, Ms. Tshilumba possesses the versatility and insight needed to navigate the intricate web of U.S. international tax regulations. Her expertise includes global mobility, expatriation tax, tax equalization, tax clauses in global assignment contracts, UN employee taxation, mergers & acquisitions, cross-border compliance, FIRPTA, delinquent foreign disclosures, and IRS controversy resolution. Ms. Tshilumba is also a Certifying Acceptance Agent (CAA) and works closely with immigration attorneys and real estate professionals to navigate U.S. tax compliance for foreign nationals.
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CPE On-Demand