Cross-Border Ownership Structures: Lessons Learned Under Tougher IRS Scrutiny

Description

By now, U.S. taxpayers have filed one or more revised IRS forms disclosing corporate foreign ownership structures, including significantly updated forms 1120-F (foreign entities) and 926 (foreign asset transfers) and changed forms 5471 and 5472 (shares in foreign companies).

Becoming adept in providing all of the data demanded in those disclosures takes time, as does adjusting to tougher IRS audit and penalty positions on foreign ownership. Starting last year, the IRS beefed up its dedicated audit staff and started charging costly penalties for late or non-filings.

Improve your compliance by learning from the experiences of tax advisors familiar with the new data demands on Forms 1120-F, 926, 5471 and 5472 and new approaches for dealing with toughened IRS oversight of foreign ownership structures.

Listen as our panel of seasoned accounting advisors helps you stay fully compliant with the IRS' evolving expectations for reporting on foreign ownership.

Outline

1. IRS enforcement and audit environment to date
   1. Background on tougher Form 5471 penalties, and frequency with which they’ve been imposed
   2. Penalty structure for forms 5472, 1120-F and 926, recent audit activity
2. Accurately completing Form 1120-F and its schedules
   1. Increased disclosure requirements for allocations of expenses
      1. New Schedules P, H and I
   2. Best practices and considerations for new schedules and information
3. Accurately completing Forms 5471 and 5472
   1. What to report on Form 5472; records and documentation of transactions
   2. Recent regulatory actions and guidance relevant to international transaction compliance
   3. Form 5471 (information return of U.S. persons with respect to foreign corporations)
4. Accurately completing Form 926
   1. New line items and information reporting on draft IRS form revisions

Benefits

The panel will prepare you for these and other crucial aspects:

• Understanding — and taking — the preventive steps to avoid costly penalties and audits.
• Planning for an IRS audit of foreign ownership connections, based on enforcement activities to date.
• Mastering the new forms, particularly new details on value, costs and gains associated with transferred assets on Form 926, as well as new disclosures of direct and indirect allocations of expenses to income on Form 1120-F.

Webinar/Teleconference

Strafford webinars/teleconferences offer several options for participation: online viewing of speaker-controlled PowerPoint presentations with audio via computer speakers or via phone; or audio only via telephone (download speaker handouts prior to the program).  Please note that our webinars do not feature videos of the presenters.

NASBA CPE Sponsor

Strafford 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 credit. Complaints regarding registered sponsors may be addressed to the National Registry of CPE Sponsors, 150 Fourth Avenue North, Suite 700, Nashville, TN, 37219-2417 or by visiting www.nasba.org.

CPE Credit

Strafford is a NASBA CPE sponsor and our live seminars qualify for CPE credits. They offer you a high quality, cost effective, and convenient CPE option, with no lost travel time or expenses.