BarbriSFCourseDetails
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Course Details

Course Information
  • smart_display Format

    On-Demand

  • signal_cellular_alt Difficulty Level

    Intermediate

  • work Practice Area

    Tax Preparer

Date & Time
  • event Date

    Thursday, March 5, 2020

  • schedule Time

    1:00 p.m. ET./10:00 a.m. PT

  • timer Program Length

    110 minutes

Credit Information

  • BARBRI is a NASBA CPE sponsor and this 110-minute webinar is accredited for 2.0 CPE credits.

  • BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).

$197.00

This course will provide tax advisers with a practical guide to completing Form 5471, Information Return of U.S. Persons With Respect to Certain Foreign Corporations. The panel will review the significant changes made to Form 5471 in light of the 2017 tax overhaul legislation and recent changes made by Revenue Procedure 2019-40 for CFC reporting and proposed regulation updates. 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.

Faculty

Dougherty Alison
Shareholder
Googolplex Tax, LLC

Ms. Dougherty provides U.S. tax reporting, compliance, consulting, planning, and structuring solutions to U.S. and foreign corporations, partnerships, LLCs, individuals, and trusts. She specializes in U.S. international tax reporting and compliance with the preparation and review of the U.S. federal Forms 5471, 926, 8992, 8993, 5472, 8865, 8858, 8621, 8804, 8805, Schedules K-2 and K-3, 1116, 1118, 1042, 1042-T, 1042-S, 8832, 8833, 2555, 3520, 3520-A, 5713, 1120-F, 1040-NR, 8288, 8288-A, 8288-B, 8233, 8840, 8843, 8854, 8938, and FBAR. Ms. Dougherty has extensive experience working with U.S. businesses and individuals with outbound activities in foreign countries. She has also worked with foreign companies and nonresident individuals with inbound activities in the United States. Ms. Dougherty has significant experience with U.S. nonresident withholding tax, foreign partnership withholding tax, and FIRPTA withholding tax. She has managed U.S. tax compliance and advisory client engagements for U.S. C corporations, S corporations, partnerships, LLCs, U.S. individuals, U.S. trusts, foreign corporations, foreign partnerships, foreign LLCs, nonresident individuals, and foreign  trusts.  Ms. Dougherty is a CPA and a tax attorney with more than 15 years of combined experience in public accounting, the practice of law, and corporate industry. She was previously a tax partner in a large regional public accounting firm in the Washington, DC area. Ms. Dougherty has served clients in various industries including technology, U.S. government contracting, commercial services, telecommunications, real estate, investment partnerships, commodities, high net worth individuals, and family offices. She has also served as a technical resource to other CPAs, accountants, tax professionals, public accounting firms, attorneys, and law firms.  

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Samtoy John
Shareholder
Holthouse Carlin & Van Trigt LLP

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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Description

Form 5471, Information Return of U.S. Persons With Respect to Certain Foreign Corporations; has long been one of the most complicated reporting obligations in the U.S. offshore information tax reporting regime, and the 2017 legislation created additional challenges, increasing both the amount of information required and the number of U.S. taxpayers obligated to file. Failure to file a "substantially complete" Form 5471, absent reasonable cause, exposes the taxpayer to severe monetary and other penalties, beginning at $10,000 per year per missed form.

Filing Form 5471 requires data reporting from simple to highly intricate. Correctly completing the form involves hours of intensive work, including proper recordkeeping and data analysis. U.S. individuals and entities that own, acquire, or dispose of shares of a foreign corporation may be required to file Form 5471 with their income tax returns. U.S. officers and directors of these foreign corporations may also have reporting responsibility.

Foreign corporation attribution rule changes under tax reform further complicate compliance. Revenue Procedure 2019-40 provides relief from specific foreign corporation reporting obligations. New for 2019, the IRS has stated its intention to amend the instructions for the form to reduce the informational reporting requirements for CFCs and some unrelated minority U.S. shareholders.

Listen as our panel of veteran advisers identifies and explains the more challenging aspects of preparing Form 5471 for U.S. owned foreign corporations. The panel will outline approaches to help you accurately identify taxpayer reporting categories, determine relevant direct, indirect and constructive ownership interests, identify common compliance mistakes, and stay ahead of IRS examination issues.

Outline

  1. Purpose of Form 5471
  2. Who is required to file
  3. Tax reform changes to attribution rules and definition of U.S. shareholder
  4. Preparation of Form 5471
  5. Changes to 2019 Form 5471 for proposed regulations
  6. 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
  • Changes to Form 5471 resulting from changes in the definition of a CFC for certain foreign corporations
  • How 2017 tax law changes to attribution rules and the definition of U.S. shareholder increases the number of U.S. taxpayers required to file Form 5471
  • New schedules added to Form 5471 by the 2017 tax reform law
  • U.S. international tax reporting rules and obligations of U.S. persons with interests in foreign corporations
  • How to avoid errors and audit red flags for the Service when reviewing Form 5471

NASBA Details

Learning Objectives

After completing this course, you will be able to:

  • Determine how the definition of U.S. shareholders subject to tax on previously deferred foreign-source income has changed
  • Understand the purposes of Form 5471, the categories of U.S. persons required to file, and the reporting requirements
  • Distinguish the tax provisions under Subpart F from the GILTI provisions
  • Ascertain the enhanced IRS reporting requirements
  • Establish the impact that the termination of prior deferral benefits for U.S. shareholders of foreign business entities have on taxpayers

Strafford Publications, Inc. 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 Credits. Complaints regarding registered sponsons may be submitted to NASBA through its website: www.nasbaregistry.org.

IRS Approved Provider

Strafford is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).