Form 5471 Attribution Rules: New Categories of Filers and Rev Proc 2019-40 Safe Harbors
Note: CLE credit is not offered on this program
Recording of a 110-minute CPE webinar with Q&A
This course will explain the attribution rules for stock ownership for individuals and entities and the filing requirements of Form 5471. Our panel of international tax experts will discuss determining direct and indirect stock ownership that can result in unexpected filing obligations.
Outline
- Form 5471 Attribution rules: an overview
- Safe harbor rules under Revenue Procedure 2019-40
- Defining CFCs, U.S. shareholders, and U.S. persons
- IRC Section 958
- Direct and indirect stock ownership
- Unrelated and related shareholders
- Category of filers
- Attribution examples
- Applicable penalties
- New Schedule R
Benefits
The panel will review these and other critical issues:
- Examining the new Form 5471 categories of filers
- Qualifying for the safe harbors under Revenue Procedure 2019-40
- Applying the Section 318(a) family attribution rules for Category 4 filers
- Determine filing requirements for categories of filers
- Decide when related and unrelated parties may have 5471 filing requirements
- Filing New Schedule R for distributions from foreign corporations
Faculty
Anthony V. Diosdi
Partner
Diosdi Ching & Liu
Mr. Diosdi is an experienced trial lawyer who regularly defends individuals and corporations in matters involving tax... | Read More
Mr. Diosdi is an experienced trial lawyer who regularly defends individuals and corporations in matters involving tax controversies and government regulatory enforcement. He also has vast experience assisting clients who find themselves with unreported or undeclared bank accounts outside the U.S. Mr. Diosdi is acknowledged as one of the nation’s leading experts in contesting penalties associated with failing to file FBARs. In addition to representing clients in tax controversy matters, he advises clients on U.S. international tax matters, including tax planning with respect to their structures and transactions. In particular, Mr. Diosdi has experience advising on issues relating to tax treaties, pre-immigration planning for foreigners moving to the U.S., expatriation planning, tax planning for foreign companies doing business in the U.S., and subpart F income minimization. More recently, he has focused on helping clients navigate U.S. tax reform, including the regimes for Global Intangible Low-Taxed Income and Foreign-Derived Intangible Income, and the new limitations on foreign tax credits.
Close
Alison N. Dougherty, CPA
Managing Member
Googolplex Tax Services
Ms. Dougherty provides U.S. tax reporting, compliance, consulting, planning, and structuring solutions to U.S. and... | Read More
Ms. Dougherty provides U.S. tax reporting, compliance, consulting, planning, and structuring solutions to U.S. and foreign corporations, partnerships, LLCs, individuals, and trusts. She specializes in U.S. international tax reporting and compliance with the preparation and review of the U.S. federal Forms 5471, 926, 8992, 8993, 5472, 8865, 8858, 8621, 8804, 8805, Schedules K-2 and K-3, 1116, 1118, 1042, 1042-T, 1042-S, 8832, 8833, 2555, 3520, 3520-A, 5713, 1120-F, 1040-NR, 8288, 8288-A, 8288-B, 8233, 8840, 8843, 8854, 8938, and FBAR. Ms. Dougherty has extensive experience working with U.S. businesses and individuals with outbound activities in foreign countries. She has also worked with foreign companies and nonresident individuals with inbound activities in the United States. Ms. Dougherty has significant experience with U.S. nonresident withholding tax, foreign partnership withholding tax, and FIRPTA withholding tax. She has managed U.S. tax compliance and advisory client engagements for U.S. C corporations, S corporations, partnerships, LLCs, U.S. individuals, U.S. trusts, foreign corporations, foreign partnerships, foreign LLCs, nonresident individuals, and foreign trusts.
Ms. Dougherty is a CPA and a tax attorney with more than 15 years of combined experience in public accounting, the practice of law, and corporate industry. She was previously a tax partner in a large regional public accounting firm in the Washington, DC area. Ms. Dougherty has served clients in various industries including technology, U.S. government contracting, commercial services, telecommunications, real estate, investment partnerships, commodities, high net worth individuals, and family offices. She has also served as a technical resource to other CPAs, accountants, tax professionals, public accounting firms, attorneys, and law firms.