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

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Conducted on Wednesday, April 29, 2009

Course Materials

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.


The IRS is more demanding than ever about disclosing a broad range of corporate foreign ownership arrangements. In September, the Service announced it will automatically slap a $10,000 fine on any taxpayer failing to file Form 5471, the return for entities that own shares in foreign corporations.

Similarly, punitive penalty structures have been set up for Form 5472, for entities with foreign shareholders, and Form 926, the report for foreign asset transfers. And, the IRS has bolstered its international audit force and started requiring more details in Form 1120-F for foreign entities.

Given the high stakes, corporate taxpayers and their advisors must stay proficient on which businesses must file Forms 5471, 5472, 926 or 1120-F and when, and the associated compliance and reporting requirements. Federal auditors are watching — and watching closely.

Listen as our panel of seasoned accounting advisors prepares you to keep your clients fully compliant with the IRS' expectations for reporting on foreign ownership.



  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


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.


William P. Elliott
William P. Elliott

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

Kirk Sinclair
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

Russell Mansky
Russell Mansky

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

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