Calculating and Reporting Foreign E&P: Categorizing PTEP, Form 5471 Schedules H, P & R, Foreign Tax Credits
Note: CLE credit is not offered on this program
Recording of a 110-minute CPE webinar with Q&A
This webinar will discuss the complications surrounding the determination of foreign earnings and profits (E&P) for controlled foreign corporations (CFCs). Our panel of foreign tax experts will discuss the complexities of the related calculations, including categorizing income, handling retroactive adjustments, and reporting foreign E&P on Form 5471 Schedules H, P, and the newly added R.
- Foreign E&P: introduction
- Ordering rules
- Previously taxed earnings and profit
- Foreign tax credits
- Retroactive allocations
The panel will cover these and other key issues:
- Reporting distributions on new Schedule R, Form 5471
- How retroactive adjustments for 163(j), QIP, and other tax act changes affect foreign E&P
- Categorizing previously taxed earnings and profits
- Reporting foreign E&P on Schedules H and P of Form 5471
- Notice 2019-01 and the ordering rules
Alison N. Dougherty, J.D., LL.M., CPA
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.Close
Patrick J. McCormick, J.D., LL.M.
Culhane Meadows Haughian & Walsh
Mr. McCormick specializes in the areas of international taxation, tax compliance, and offshore reporting... | Read More
Mr. McCormick specializes in the areas of international taxation, tax compliance, and offshore reporting obligations. He published national articles and given numerous national and local presentations on assorted areas of tax and estate planning law, including international tax and offshore compliance issues. His latest article on PFICs is titled Tax Reporting Implications of Foreign Mutual Funds. He is licensed to practice in the States of New Jersey, Florida, and Georgia, and the Commonwealth of Pennsylvania.Close
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CPE credit is not available on downloads.