Offshore Ownership Structures: Lessons Learned Under Tough IRS Scrutiny
Complying With Foreign Information Reporting Forms 5471, 5472, 1120F and 926
Note: CLE credit is not offered on this program
Recording of a 110-minute CPE webinar with Q&A
This course will prepare corporate tax executives and advisers with a useful survey of the reporting requirements for U.S. companies with cross-border structures. The panel will outline the significant changes and challenges to completing Forms 5471, 5472, 1120-F and 926 with practical experiences geared toward improving compliance. The panel will provide insights to deal with IRS policies on audits and penalties.
Outline
- IRS enforcement and audit environment to date
- Mechanics and overview of foreign information reporting requirements
- Form changes and new reporting requirements brought about by 2017 tax reform law
- Forms 5471 and 5472 compliance issues
- GILTI
- Form 926
- Form 1120-F
- IRS enforcement and audit environment to date
- Background on stricter Form 5471 penalties and frequency with which they've been imposed
- The penalty structure for Forms 5472, 1120-F and 926; recent audit activity
- New foreign compliance campaigns
- Expiration of OVDP and replacement voluntary compliance programs
- Form changes and new reporting requirements brought about by 2017 tax reform law
- Forms 5471 and 5472 compliance issues
- GILTI
- Form 926
- Form 1120-F
Benefits
The panel will prepare you for these and other crucial aspects:
- Understanding--and taking--the preventive steps to avoid costly penalties and interest, branch profits tax assessments, audits, and other adverse events
- Planning for an IRS audit of foreign ownership connections based on enforcement activities to date
- Mastering the details regarding the value, costs and gains on transferred assets, direct and indirect expense allocations, and other disclosures required on forms 5471, 5472, 1120-F and 926
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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