Form 5471 Schedule J, Accumulated Earnings of Controlled Foreign Corporation: Line-by-Line
Deep Dive Into Additional Categories, Classifications, and Sections of Complex Schedule J
Recording of a 110-minute CPE webinar with Q&A
This webinar will provide tax advisers with a practical, in-depth guide to completing Form 5471's recently revised Schedule J, Accumulated Earnings & Profits (E&P) of Controlled Foreign Corporations. The panel will take a line-by-line approach to the form, discussing each of the income items listed in the various sub-sections of IRC 959, and detail how to identify the Nonpreviously Taxed E&P Subject to Recapture as Subpart F Income required in Part II. This is an advanced level webinar for attendees well-versed in prior revisions of Form 5471.
Outline
- Prior versions of Schedule J
- Seven (7) lines of calculations
- Five (5) columns of income/E&P classifications
- All references to post-1986 balances and carry-forward amounts
- Income classifications in revised Schedule J
- Calculation questions
- Part II Nonpreviously Taxed E&P Subject to Recapture as Subpart F Income (Section 952(c)(2))
Benefits
The panel will discuss these and other specific changes to Schedule J:
- Lines and columns required to report accumulated E&P balances concerning categories of previously taxed E&P necessitated by income inclusions under Section 965(a) and GILTI
- How this schedule incorporates Subpart F inclusions and recaptures
- How to handle deficit calculations after nonrecognition transactions
- Reclassification lines
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.
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Alison N. Dougherty, J.D., LL.M., CPA
Partner
Aronson
Ms. Dougherty specializes in U.S. international tax reporting, compliance, consulting, planning, and structuring as a... | Read More
Ms. Dougherty specializes in U.S. international tax reporting, compliance, consulting, planning, and structuring as a significant contributor to the firm’s international tax practice. She has extensive experience assisting clients with U.S. tax reporting and compliance for offshore assets and foreign accounts. Ms. Dougherty provides outbound U.S. international tax guidance to U.S. individuals and businesses with activities in other countries. She also provides inbound U.S. international tax guidance to nonresident individuals and businesses with activities in the U.S. Ms. Dougherty has counseled U.S. taxpayers regarding the outbound formation, capitalization, acquisition, operation, reorganization, and liquidation of foreign companies. She has significant experience with U.S. federal nonresident tax withholding, foreign partner tax withholding, and FIRPTA withholding. She works closely with nonresident individuals and businesses regarding inbound U.S. real property investment. Additionally, Ms. Dougherty has assisted U.S. taxpayers with IRS amnesty program disclosures of offshore assets and foreign accounts.
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