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Form 5471 for Interests in Foreign Entities: CFC Reporting Relief, Determining Ownership Share and Filing Status

Note: CLE credit is not offered on this program

Recording of a 110-minute CPE webinar with Q&A

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Conducted on Thursday, March 5, 2020

Recorded event now available

or call 1-800-926-7926

This course will provide tax advisers with a practical guide to completing Form 5471, Information Return of U.S. Persons With Respect to Certain Foreign Corporations. The panel will review the significant changes made to Form 5471 in light of the 2017 tax overhaul legislation and recent changes made by Revenue Procedure 2019-40 for CFC reporting and proposed regulation updates. The webinar will discuss correctly identifying taxpayer categories, focusing on taxpayers with new filing duties, and will offer approaches on avoiding severe, but common, mistakes in completing the form.


Form 5471, Information Return of U.S. Persons With Respect to Certain Foreign Corporations; has long been one of the most complicated reporting obligations in the U.S. offshore information tax reporting regime, and the 2017 legislation created additional challenges, increasing both the amount of information required and the number of U.S. taxpayers obligated to file. Failure to file a "substantially complete" Form 5471, absent reasonable cause, exposes the taxpayer to severe monetary and other penalties, beginning at $10,000 per year per missed form.

Filing Form 5471 requires data reporting from simple to highly intricate. Correctly completing the form involves hours of intensive work, including proper recordkeeping and data analysis. U.S. individuals and entities that own, acquire, or dispose of shares of a foreign corporation may be required to file Form 5471 with their income tax returns. U.S. officers and directors of these foreign corporations may also have reporting responsibility.

Foreign corporation attribution rule changes under tax reform further complicate compliance. Revenue Procedure 2019-40 provides relief from specific foreign corporation reporting obligations. New for 2019, the IRS has stated its intention to amend the instructions for the form to reduce the informational reporting requirements for CFCs and some unrelated minority U.S. shareholders.

Listen as our panel of veteran advisers identifies and explains the more challenging aspects of preparing Form 5471 for U.S. owned foreign corporations. The panel will outline approaches to help you accurately identify taxpayer reporting categories, determine relevant direct, indirect and constructive ownership interests, identify common compliance mistakes, and stay ahead of IRS examination issues.



  1. Purpose of Form 5471
  2. Who is required to file
  3. Tax reform changes to attribution rules and definition of U.S. shareholder
  4. Preparation of Form 5471
  5. Changes to 2019 Form 5471 for proposed regulations
  6. IRS enforcement and audit environment to date
    1. Background on Form 5471 penalties
    2. Penalty structure for Form 5471
    3. Use of Form 5471 as an IRS audit tool


The panel will review these and other crucial concepts:

  • Understand the purpose of Form 5471, the categories of U.S. persons required to file, and reporting requirements
  • Changes to Form 5471 resulting from changes in the definition of a CFC for certain foreign corporations
  • How 2017 tax law changes to attribution rules and the definition of U.S. shareholder increases the number of U.S. taxpayers required to file Form 5471
  • New schedules added to Form 5471 by the 2017 tax reform law
  • U.S. international tax reporting rules and obligations of U.S. persons with interests in foreign corporations
  • How to avoid errors and audit red flags for the Service when reviewing Form 5471


Dougherty, Alison
Alison N. Dougherty, J.D., LL.M., CPA


Ms. Dougherty specializes in U.S. international tax reporting, compliance, consulting, planning, and structuring as a...  |  Read More

Samtoy, John
John Samtoy

Tax Partner
Holthouse Carlin & Van Trigt

Mr. Samtoy’s practice specializes in international tax compliance and consulting services, with a focus on...  |  Read More

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