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

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

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


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.

EA Credit

Enrolled Agent credit processing is available for an additional fee per person.

EA Processing $5.00


Recorded Event

Includes full event recording plus handouts.

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

Recorded Webinar Download $247.00

How does this work?

Recorded Audio Download (MP3) $247.00

How does this work?


National Registry of CPE Sponsors

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 credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its website:

IRS Approved Provider

Strafford is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).

Program Materials

Requires Adobe Reader 8 or later. Download Acrobat FREE.

Program Materials

Requires Adobe Reader 8 or later. Download Acrobat FREE.

or call 1-800-926-7926

CPE Credit

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

or call 1-800-926-7926

EA Credit

Strafford is an IRS approved continuing education provider and this course is approved for 2 enrolled agent (EA) credit hours.

or call 1-800-926-7926

Customer Reviews

I liked that the PowerPoint slides would automatically change as the speaker's presentation progressed.

Zeeshan Elahi


Provided a lot of information. Examples made it easier to put in everyday perspective.

Therese Au

Forsythe Technology

I liked the clear and concise manner in which the topics were presented.

Angelina Johnson-Brown

General Electric Company

Offered different view points and real life, practical examples.

Angela Chretin

Northrop Grumman

Real life examples that we could relate to.  Keep up the great work.

Brett Terrebonne


or call 1-800-926-7926

Corporate Tax Advisory Board

David Adler

Director of Multistate Tax Services

Deloitte Tax

Silvia Aguirre

Chief Certificate Officer


David Bowen


Grant Thornton

Elizabeth Bowman

Tax Research Analyst

ADP Tax Credit Services

Rick Bregitzer

Manager of Domestic Taxes


Joseph Calianno

Partner, National Tax Office International Tax


Patrick Derdenger

Tax Partner

Steptoe & Johnson

Martin Eisenstein

Managing Partner

Brann & Isaacson

John Garippa

Senior Partner

Garippa Lotz & Giannuario

Joseph Geiger, Esq., CPA

Tax Consultant


Kenneth Graeber

VP & Management Consultant

Marvin F. Poer & Co.

Don Griswold

Executive Tax Counsel

Berkshire Hathaway Tax Group

Stephanie Anne Lipinski-Galland


Williams Mullen

George Manousos



Diane Matulich

Senior Manager, Local Taxes

Advanced Micro Devices

Betty McIntosh

Senior Managing Director

Cushman & Wakefield

Foy Mitchell

Vice President

Marvin F. Poer & Co.

Richard Pomp

Professor of Tax Law

University of Connecticut

Walter Pickhardt


Faegre Baker Daniels

Richard J. Prem

Vice President, Indirect Taxes & Tax Reporting

Michael Press


Scout Economics

Tammy Propst



Mark Semerad

Manager of Property Tax

Level 3 Communications

Richard Weiss

Tax Research Manager

ADP Tax Credit Services

Tom Windram

Managing Director & National Leader, Federal Tax Credits & Incentives

RSM McGladrey

Thomas Zaino

Managing Member

Zaino Hall & Farrin

or call 1-800-926-7926

Our Guarantee

Strafford webinars are backed by our 100% Unconditional Money-Back Guarantee: if you are not satisfied with any of our products, simply let us know and get a full refund. For more information regarding complaints and refunds, please contact us at 1-800-926-7926 ext 10. Complaints regarding this program can be submitted via the course evaluation found in the “Thank you” e-mail at the end of the course.