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

Complying With Forms 5471, 5472, 1120F and 926

Recording of a 110-minute CPE webinar with Q&A

Conducted on Thursday, August 10, 2017

Recorded event now available

or call 1-800-926-7926
Program Materials

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.


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.



  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


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


Dougherty, Alison
Alison N. Dougherty, J.D., LL.M.


Ms. Dougherty has extensive experience assisting clients with U.S. tax reporting and compliance for offshore assets and...  |  Read More

Samtoy, John
John Samtoy

Tax Principal
Holthouse Carlin & Van Trigt

Mr. Samtoy’s practice specializes in international tax compliance and consulting services, with a focus on...  |  Read More

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