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

Complying With Forms 5471, 5472, 1120F and 926

A live 110-minute CPE webinar with interactive Q&A


Thursday, August 10, 2017
1:00pm-2:50pm EDT, 10:00am-11:50am PDT


This webinar will prepare corporate tax executives and advisers working on 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.

Description

U.S. taxpayers face challenges with timely and accurately filing IRS forms disclosing corporate foreign ownership structures. The different forms required include 1120-F (foreign entities) and 926 (foreign asset transfers) and changed forms 5471 and 5472 (shares in foreign companies).

Since these forms were overhauled, data and time demands on tax advisers and payers have not abated. Meanwhile, U.S. companies are grappling with IRS audit emphasis on foreign business structures and face costly penalties and interest, and branch profits tax, for mistaken or late disclosures.

Improve your client’s or company’s compliance by learning from the real world experiences of tax advisers familiar with data demands from Forms 1120-F, 926, 5471 and 5472, and who are veterans in dealing with IRS oversight of foreign ownership structures.

Listen as our panel of seasoned accounting advisers 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. Forms 5471 and 5472
    1. Difficult compliance issues
  3. Form 1120-F and its schedules
    1. Difficult compliance issues
  4. Form 926
    1. Difficult compliance issues

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 negative events
  • Planning for an IRS audit of foreign ownership connections based on enforcement activities to date
  • Mastering the details regarding value, costs and gains on transferred assets, direct and indirect expense allocations, and other disclosures required on forms 5471, 5472, 1120-F and 926

Learning Objectives

Upon completion of this webinar, you will be able to:

  • Identify the data demands on forms 5471, 5472, 1120-F and 926
  • Recognize penalty structure for forms 5471, 5472, 1120-F and 926
  • Discern details regarding value, costs and gains on transferred assets, direct and indirect expense allocations, and other required disclosures

Faculty

Alison N. Dougherty, J.D., LL.M., Director
Aronson, Rockville, Md.

Ms. Dougherty has extensive experience assisting clients with U.S. tax reporting and compliance for offshore assets and foreign accounts. She specializes in international tax compliance, planning and structuring as a subject matter leader of her firm's international tax practice. Her responsibilities include U.S. Federal and multi-state tax compliance for C corporations, S corporations, partnerships and individuals. She also provides transactional tax planning and structuring services.

John Samtoy, Tax Principal
Holthouse Carlin & Van Trigt, Costa Mesa, Calif.

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.


Registration per Person for Live Event

Live Webinar $247.00

Live Webinar & CPE Processing $282.00


CPE per Person on Live Event

Continuing Professional Education credit processing is available for an additional fee. CPE processing must be ordered prior to the event. To qualify for CPE you may not listen via the telephone.

This program is eligible for 2.0 CPE credits.

  • 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 verification codes announced throughout the presentation.
  • Prerequisite: Three years+ business or public firm experience at mid-level within the organization, preparing complex tax forms and schedules; supervisory authority over other preparers/accountants. Knowledge and familiarity with corporate foreign ownership structures, forms 1120-F, 926, 5471 and 5472 and their accompanying schedules.

NOTE: CPE credit processing for all attendees must be ordered by 2pm Eastern the day of the program to receive a Certificate of Attendance within 24 hours.


Recordings

Recorded Event

Includes full event recording plus handouts (available after live webinar).

Note: Self-study CPE and EA credits are not offered on recorded events.

Recorded Webinar Download $247.00
Available 48 hours after the live event

How does this work?

Recorded Audio Download (MP3) $247.00
Available 24 hours after the live event

How does this work?

DVD (Slide Presentation with Audio) $247.00 plus $9.45 S&H
Available ten business days after the live event

How does this work?


Registration Plus Recorded Event

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Live Webinar & Webinar Download $344.00

Recorded Webinar Download Only $97.00 with Registration/Webinar Combo

Live Webinar & Audio Download $344.00

Recorded Audio Download (MP3) Only $97.00 with Registration/MP3 Combo

Live Webinar & DVD $344.00 plus $9.45 S&H

DVD (Slide Presentation with Audio) Only $97.00 with Registration/DVD Combo


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Customer Reviews

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Senior Partner

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George Manousos

Partner

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Diane Matulich

Senior Manager, Local Taxes

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Betty McIntosh

Senior Managing Director

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Foy Mitchell

Vice President

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Walter Pickhardt

Partner

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Richard Pomp

Professor of Tax Law

University of Connecticut

Richard J. Prem

Vice President, Indirect Taxes & Tax Reporting

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President

Scout Economics

Tammy Propst

President

taxadvantagegroup

Mark Semerad

Manager of Property Tax

Level 3 Communications

Richard Weiss

Tax Research Manager

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Managing Director & National Leader, Federal Tax Credits & Incentives

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Thomas Zaino

Managing Member

Zaino Hall & Farrin

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