Form 5471 for Interests in Foreign Entities After Tax Reform
New Schedules, Determining Ownership Share and Correct Filing Status
Note: CLE credit is not offered on this program
Recording of a 110-minute CPE webinar with Q&A
This course will provide tax advisers with a practical guide to completing the new Form 5471, Information Return of U.S. Persons With Respect to Certain Foreign Corporations. The panel will detail the significant changes made to Form 5471 in light of the 2017 tax overhaul legislation. The webinar will discuss correctly identifying taxpayer categories, focusing on taxpayers with new filing duties, and will offer approaches on avoiding severe, but common, mistakes in completing the form.
Outline
- Purpose of Form 5471
- Who is required to file
- Tax reform changes to attribution rules and definition of U.S. shareholder
- Preparation of Form 5471
- New schedules added by 2017 tax reform law
- IRS enforcement and audit environment to date
- Background on Form 5471 penalties
- Penalty structure for Form 5471
- Use of Form 5471 as an IRS audit tool
Benefits
The panel will review these and other crucial concepts:
- Understand the purpose of Form 5471, the categories of U.S. persons required to file, and reporting requirements
- How 2017 tax law changes to attribution rules and the definition of U.S. shareholder likely increases the number of U.S. taxpayers required to file Form 54712
- New schedules added to Form 5471 by the 2017 tax reform law
- Grasp U.S. international tax reporting rules and obligations of U.S. persons with interests in foreign corporations
- Avoid errors and audit red flags for the Service when reviewing Form 5471
Faculty
Alison N. Dougherty, J.D., LL.M., CPA
Partner
Aronson
Ms. Dougherty specializes in U.S. international tax reporting, compliance, consulting, planning, and structuring as a... | Read More
Ms. Dougherty specializes in U.S. international tax reporting, compliance, consulting, planning, and structuring as a significant contributor to the firm’s international tax practice. She has extensive experience assisting clients with U.S. tax reporting and compliance for offshore assets and foreign accounts. Ms. Dougherty provides outbound U.S. international tax guidance to U.S. individuals and businesses with activities in other countries. She also provides inbound U.S. international tax guidance to nonresident individuals and businesses with activities in the U.S. Ms. Dougherty has counseled U.S. taxpayers regarding the outbound formation, capitalization, acquisition, operation, reorganization, and liquidation of foreign companies. She has significant experience with U.S. federal nonresident tax withholding, foreign partner tax withholding, and FIRPTA withholding. She works closely with nonresident individuals and businesses regarding inbound U.S. real property investment. Additionally, Ms. Dougherty has assisted U.S. taxpayers with IRS amnesty program disclosures of offshore assets and foreign accounts.
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John Samtoy
Tax Partner
Holthouse Carlin & Van Trigt
Mr. Samtoy’s practice specializes in international tax compliance and consulting services, with a focus on... | Read More
Mr. Samtoy’s practice specializes in international tax compliance and consulting services, with a focus on individuals, closely-held businesses, and hedge funds. He has particular expertise in structuring and reporting foreign manufacturing arrangements and foreign holding companies, and is experienced in foreign asset disclosure requirements, as well as foreign trust and estate reporting.
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