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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

    Wednesday, December 20, 2023

  • 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
CPE
ALL

This course will explain and simplify the preparation of Form 5471, Schedules J, P, H, and E for tax preparers grappling with the requirements of these detailed schedules, including the most recent changes made to these schedules.

Faculty

Anthony V. Diosdi
Partner
Diosdi & Liu, LLP

Mr. Diosdi is an experienced trial lawyer who regularly defends individuals and corporations in matters involving tax controversies and government regulatory enforcement. He also has vast experience assisting clients who find themselves with unreported or undeclared bank accounts outside the U.S. Mr. Diosdi is acknowledged as one of the nation’s leading experts in contesting penalties associated with failing to file FBARs. In addition to representing clients in tax controversy matters, he advises clients on U.S. international tax matters, including tax planning with respect to their structures and transactions. In particular, Mr. Diosdi has experience advising on issues relating to tax treaties, pre-immigration planning for foreigners moving to the U.S., expatriation planning, tax planning for foreign companies doing business in the U.S., and subpart F income minimization. More recently, he has focused on helping clients navigate U.S. tax reform, including the regimes for Global Intangible Low-Taxed Income and Foreign-Derived Intangible Income, and the new limitations on foreign tax credits.

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Alison N. Dougherty
Managing Member
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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Description

Properly preparing Form 5471, Information Return of U.S. Persons with Respect to Certain Foreign Corporations, and its related Schedules J, P, H, and E is complex and crucial. With penalties of $10,000 for not filing the form itself and foreign tax credits at stake, not getting this form and its schedules right could prove costly. Preparing this form requires understanding the underlying and perpetually changing foreign rules that govern this reporting obligation.

Legislative changes have dictated continual changes to Form 5471. Schedule J and Schedule P report accumulated E&P and previously taxed E&P (PTEP) respectively of a CFC in its functional currency. Foreign income is reported in one of six categories with an appropriate code, 951A, RBT (income re-source by treaty), 901(j) (income earned from a sanctioned country), FB (QBUs), in addition to the more familiar passive and general income categories.

Schedule H, Current E&P, is completed by Category 4 and 5 filers to report the foreign corporation's E&P in the CFC's functional currency. Preparing this form includes making appropriate foreign book adjustments to comply with U.S. GAAP and tax reporting requirements.

Schedule E contains seven columns that necessitate reporting accurately and claiming the foreign tax credit after tax reform. Preparers must understand the limitation on FTCs imposed by Sections 901 (what constitutes a tax) and 909 (foreign tax credit splitting) when completing this schedule. Numerous updates have been made to Schedule E this year, including a new "TOTAL" code required for certain taxpayers. Pages 2 and 3 of Schedule E-1 require that taxpayers report amounts in all columns, including column (c), in U.S. dollars rather than the functional currency.

Listen as our panel provides expert insights into the preparation of Schedules J, P, H, and E with Form 5471 and the underlying regulations that mandate their preparation.

Outline

  1. Form 5471: an overview
  2. Underlying rules and regulations
  3. Anticipated guidance
  4. Schedule E, Income, War Profits, and Excess Profits Taxes Paid or Accrued
  5. Schedule H, Current E&P
  6. Schedule J, Accumulated E&P of CFCs
  7. Schedule P, PTEP of U.S. Shareholder of CFCs

Benefits

The panel will review these and other critical issues:

  • Determining which category filers are required to complete Schedules J, P, H, and E of Form 5471
  • Categorizing foreign income into the required categories on Schedule J
  • Understanding the applicable Code sections and regulations relative to Schedules J, P, H, and E of Form 5471
  • Identifying foreign income that is creditworthy

NASBA Details

Learning Objectives

After completing this course, you will be able to:

  • Understand the purposes of Form 5471 and various schedules, the categories of U.S. persons required to file, and the reporting requirements
  • Determine which category of filers are required to complete Schedules J, P, H, and E of Form 5471
  • Identify when shareholders of CFCs are subject to reporting requirements
  • Categorize foreign income into required categories on Schedule J
  • Ascertain foreign income that is creditworthy

  • Field of Study: Taxes
  • Level of Knowledge: Intermediate
  • Advance Preparation: None
  • Teaching Method: Seminar/Lecture
  • Delivery Method: Group-Internet (via computer)
  • Attendance Monitoring Method: Attendance is monitored electronically via a participant's PIN and through a series of attendance verification prompts displayed throughout the program
  • Prerequisite: Three years+ business or public firm experience preparing complex tax forms and schedules, supervising other preparers or accountants. Specific knowledge and understanding of pass-through taxation, including taxation of partnerships, S corporations and sole proprietorships, qualified business income, net operating losses and loss limitations; familiarity with net operating loss carry-backs, carry-forwards and carried interests.

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).