Cross Border Ownership Structures Under Heightened IRS Scrutiny
Mastering the Compliance Challenges of Forms 1120-F, 5471, 5472 and 926
100-Minute CPE Teleconference plus 25 Minutes of Interactive Q&A
Recording of a 125-minute CPE webinar with Q&A
This seminar will review recent changes to federal regulations and applicable IRS guidance for corporate tax executives and accounting advisors to ensure complete and accurate reporting of foreign ownership structures on forms 1120-F, 5471, 5472 and 926.
Outline
- IRS enforcement and audit environment
- Background on tougher Form 5471 penalties
- Penalty structure for forms 5472, 1120-F and 926, recent audit activity
- Accurately completing Form 1120-F and its schedules
- What companies must file Form 1120-F
- Revisions drafted by IRS May 2007
- Increased disclosure requirements for allocations of expenses
- New Schedules P, H and I
- Best practices and considerations for new schedules and information
- Accurately completing Forms 5471 and 5472
- Form 5472 (information return for foreign-owned U.S. corporations)
- What to report on Form 5472; records and documentation of transactions
- Recent regulatory actions and guidance relevant to international transaction compliance
- Form 5471 (information return of U.S. persons with respect to foreign corporations)
- Form 5472 (information return for foreign-owned U.S. corporations)
- Accurately completing Form 926
- New line items and information reporting on draft IRS form revisions
- Status update of the revised form
Benefits
The panel will leave you better prepared in these and other crucial aspects:
- Understanding — and taking — the preventive steps that will avoid costly penalties and audits.
- Reviewing the current draft version of Form 926, which requires more detail about the value, costs and gains associated with transferred assets.
- Mastering the 2008 revisions to form 1120-F to ensure accurate compliance, including new disclosures of direct and indirect allocations of expenses to income.
Following the speaker presentations, you'll have an opportunity to get answers to your specific questions during the interactive Q&A.
Faculty

William P. Elliott
Partner
Cherry Bekaert & Holland
He is the firm's lead International Tax Partner, with over 25 years of tax planning and compliance experience. He... | Read More
He is the firm's lead International Tax Partner, with over 25 years of tax planning and compliance experience. He specializes in advising a wide array of industries on the tax implications of cross-border transactions.
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Kirk Sinclair
Senior Tax Accountant
Holtz Rubenstein Reminick
He focuses on U.S. taxation of foreign source income and foreign persons. He assists clients with tax services focusing... | Read More
He focuses on U.S. taxation of foreign source income and foreign persons. He assists clients with tax services focusing on international tax compliance and planning.
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Russell Mansky
Partner
Spott Lucey & Wall
He is the CPA firm's lead specialist on controlled foreign corporations and an income tax compliance expert. He works... | Read More
He is the CPA firm's lead specialist on controlled foreign corporations and an income tax compliance expert. He works with professional, closely held and foreign corporation clients.
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CPE credit is not available on downloads.
On-Demand Seminar Audio