Form 1120-F Reporting for Foreign Corporations: Filing Obligations Under IRS Scrutiny

Effectively Connected Income, Permanent Establishment and Treaty Position Exemption Claims, Protective Returns

A live 110-minute CPE webinar with interactive Q&A

Tuesday, October 10, 2017
1:00pm-2:50pm EDT, 10:00am-11:50am PDT

Early Registration Discount Deadline, Friday, September 22, 2017

This webinar will provide corporate tax professionals with a solid and practical guide to Form 1120-F. The panel will focus on the key schedules unique to Form 1120-F, discuss the permanent establishment rules, and offer useful guidance in filing protective returns and other strategies to avoid IRS audit challenges.


The IRS recently announced it will address Form 1120-F noncompliance as a focus of its Large Business and International Division’s Audit and Compliance Campaign. The announcement signals a change in the Service’s emphasis and follows data findings that 1120-F non-filing is widespread and increasing.

Foreign corporations must file Form 1120-F if they engaged in a trade or business in the United States, or had income, gain or loss that would be treated as effectively connected with the conduct of a U.S. trade or business. Filing obligations go further than these two criteria: a corporation taking the position that it avoided having a permanent establishment in the U.S. or claiming some other income tax treaty benefit must also file to document that position.

Foreign corporations with only limited activities may file a “protective return” to preserve tax benefits if an IRS examination later proves the corporation should have filed a return.

While Form 1120-F is similar in structure to the income tax return of a domestic corporation in terms of information required, taxpayers filing an 1120-F also must allocate U.S. source and foreign source income and deductions. Tax advisers need to know the rules for determining income sourcing to avoid tax consequences.

Listen as our experienced panel provides a practical guide to completing Form 1120-F, including determination of filing requirements and other audit avoidance strategies, and completing schedules specific to Form 1120-F.


  1. Form 1120-F filing requirements: Who must file
  2. Transactions subject to 1120-F filing obligations
  3. Treaty provisions
  4. Protective returns
  5. Exceptions
  6. IRS audit priority campaign


The panel will discuss these and other important topics:

  • Permanent establishment issues and challenges
  • Types of corporations that must file
  • Filing Form 1120-F to claim a treaty benefit
  • Protective returns
  • How the IRS will pursue its examination campaign of noncompliant corporations
  • Penalties for delinquence

Learning Objectives

After completing this course, you will be able to:

  • Identify foreign corporations and transactions that require filing Form 1120-F
  • Recognize the income sourcing and attribution rules for allocating a foreign corporation’s U.S. taxable income
  • Discern how to use Form 1120-F as part of a tax treaty position
  • Determine when to file Form 1120-F as a protective return


Stanley Barsky, Partner
Fox Rothschild, New York

Mr. Barsky's practice involves a broad range of transactional and general advisory tax law matters, with a focus on international tax issues. He represents clients in connection with taxable and tax-free M&A transactions, both in the domestic and cross-border contexts. He also advises U.S. businesses on establishing and expanding foreign operations as well as foreign nationals and businesses on establishing and expanding U.S. operations and investing in U.S. real estate. His practice also involves advising foreign nationals on restructuring their business and personal holdings in connection with becoming U.S. residents.

Kimberlee S. Phelan, CPA, MBA, Tax Partner
WithumSmith+Brown, Princeton, N.J.

Ms. Phelan has more than 15 years of tax and accounting experience at national and regional accounting firms. Her work emphasizes inbound and outbound international structuring, corporate tax research and planning, individual tax and executive compensation planning.

Dirk Gifford, Tax Managing Director, International Corporate Services
KPMG, McLean, Va.

Mr. Gifford serves as a Tax Managing Director in the Tysons Corner office of KPMG's International Corporate Services practice. He focuses on working primarily with U.S. and foreign-owned multinational corporate clients with either U.S. inbound or outbound activities. He is experienced in complex structuring planning, provision preparation assistance and review, and tax compliance preparation for companies in the communications, financial services, and defense contractor industries. He is a frequent author and speaker on tax issues.

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.

Registration per Person for Live Event

Live Webinar $197.00

Includes Early Discount Savings of $50.00 (through 09/22/17)

Live Webinar & CPE Processing $232.00

Includes Live Webinar Early Discount Savings of $50.00 (through 09/22/17)

CPE per Person on Live Event

Continuing Professional Education credit processing is available for an additional fee. CPE processing must be ordered prior to the event. To qualify for CPE you may not listen via the telephone.

This program is eligible for 2.0 CPE credits.

  • Field of Study: Taxes.
  • Level of Knowledge: Intermediate.
  • Advance Preparation: None.
  • Teaching Method: Seminar/Lecture.
  • Delivery Method: Group-Internet (via computer).
  • Attendance Monitoring Method: Attendance is monitored electronically via a participant's PIN and through a series of verification codes announced throughout the presentation.
  • Prerequisite: Three years+ business or public firm experience at mid-level within the organization, preparing complex tax forms and schedules, supervising other preparers/accountants. Specific knowledge and understanding of effectively-connected income sourcing rules, tax treaty and permanent establishment provisions.

NOTE: CPE credit processing for all attendees must be ordered by 2pm Eastern the day of the program to receive a Certificate of Attendance within 24 hours.


Recorded Event

Includes full event recording plus handouts (available after live webinar).

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

Recorded Webinar Download $197.00
Available 48 hours after the live event

Includes Early Discount Savings of $50.00 (through 09/22/17)

How does this work?

Recorded Audio Download (MP3) $197.00
Available 24 hours after the live event

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How does this work?

DVD (Slide Presentation with Audio) $197.00 plus $9.45 S&H
Available ten business days after the live event

Includes Early Discount Savings of $50.00 (through 09/22/17)

How does this work?

Registration Plus Recorded Event

Best value!

Live Webinar & Webinar Download $294.00

Includes Special Savings of $200.00 (through 09/22/17)

Live Webinar & Audio Download $294.00

Includes Special Savings of $200.00 (through 09/22/17)

Live Webinar & DVD $294.00 plus $9.45 S&H

Includes Special Savings of $200.00 (through 09/22/17)


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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).

Early Registration
Discount Deadline
September 22, 2017
(about 9 hours)

or call 1-800-926-7926

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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

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