Form 5471 Schedules J, P, H, E: Calculating and Reporting E&P and Foreign Tax Credits

An encore presentation featuring live Q&A

A 110-minute CPE webinar with interactive Q&A


Tuesday, January 5, 2021

1:00pm-2:50pm EST, 10:00am-11:50am PST

Early Registration Discount Deadline, Friday, December 11, 2020

or call 1-800-926-7926

This webinar will explain and simplify the preparation of Form 5471, Schedules J, P, H, and E for tax preparers grappling with the preparation of these detailed schedules after the multitude of changes made by recent tax reform.

Description

Properly preparing Form 5471, Information Return of U.S. Persons with Respect to Certain Foreign Corporations, and its related Schedules J, P, H, and E is complex and crucial. With penalties of $10,000 for not filing the form itself and foreign tax credits at stake not getting this form and its schedules right, could prove costly. Preparing this form requires an understanding of the underlying and perpetually changing foreign rules that govern this reporting obligation.

Tax reform changes dictated massive changes to Form 5471. Schedule J and the newly added Schedule P report accumulated E&P and previously taxed E&P (PTEP) respectively of a CFC in its functional currency. Foreign income is reported in one of six categories with an appropriate code, 951A, RBT (income re-source by treaty), 901(j) (income earned from a sanctioned country), FB (QBUs) in addition to the more familiar passive and general income categories.

Schedule H, Current E&P, is completed by Category 4 and 5 filers to report the foreign corporation's E&P in the CFC's functional currency. Preparing this form includes making appropriate adjustments for the foreign books to comply with U.S. GAAP and tax reporting requirements.

Schedule E contains seven new columns necessitated to accurately report and claim the foreign tax credit after tax reform. Preparers must understand the limitation on FTCs imposed by Sections 901 (what constitutes a tax) and 909 (foreign tax credit splitting) when completing this schedule. A separate schedule E1 is required for each category of income. Completing this form is necessary to claim the FTC for foreign taxes paid.

Listen as our panel provides expert insights into the preparation of Schedules J, P, H, and E with Form 5471 and the underlying regulations that mandate their preparation.

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Outline

  1. Form 5471: an overview
  2. Underlying rules and regulations
  3. Anticipated guidance
  4. Schedule E, Income, War Profits, and Excess Profits Taxes Paid or Accrued
  5. Schedule H, Current E&P
  6. Schedule J, Accumulated E&P of CFCs
  7. Schedule P, PTEP of U.S. Shareholder of CFCs

Benefits

The panel will review these and other critical issues:

  • Determining which category filers are required to complete Schedules J, P, H, and E of Form 5471
  • Categorizing foreign income into the required categories on Schedule J
  • Understanding the applicable code sections and regulations relative to Schedules J, P, H, and E of Form 5471
  • Identifying foreign income that is creditworthy

An encore presentation with live Q&A.

Faculty

Diosdi, Anthony
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

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

Director, Tax Services
Aronson

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

Skinner, William
William R. Skinner

Partner
Fenwick & West

Mr. Skinner focuses his practice on U.S. international taxation, with a particular emphasis on tax planning and...  |  Read More

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