Cross Border Ownership Structures Under Heightened IRS Scrutiny

Outline

1. IRS enforcement and audit environment
   1. Background on tougher Form 5471 penalties
   2. Penalty structure for forms 5472, 1120-F and 926, recent audit activity
2. Accurately completing Form 1120-F and its schedules
   1. What companies must file Form 1120-F
   2. Revisions drafted by IRS May 2007
      1. Increased disclosure requirements for allocations of expenses
      2. New Schedules P, H and I
   3. Best practices and considerations for new schedules and information
3. Accurately completing Forms 5471 and 5472
   1. Form 5472 (information return for foreign-owned U.S. corporations)
      1. What to report on Form 5472; records and documentation of transactions
      2. Recent regulatory actions and guidance relevant to international transaction compliance
   2. Form 5471 (information return of U.S. persons with respect to foreign corporations)
4. Accurately completing Form 926
   1. New line items and information reporting on draft IRS form revisions
   2. 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.