Form 5471 Schedules J, P, H, E: Calculating and Reporting E&P and Foreign Tax Credits
Note: CLE credit is not offered on this program
Recording of a 110-minute CPE webinar with Q&A
This course will explain and simplify the preparation of Form 5471, Schedules J, P, H, and E for tax preparers grappling with the requirements of these detailed schedules, including the most recent changes made to these schedules.
Outline
- Form 5471: an overview
- Underlying rules and regulations
- Anticipated guidance
- Schedule E, Income, War Profits, and Excess Profits Taxes Paid or Accrued
- Schedule H, Current E&P
- Schedule J, Accumulated E&P of CFCs
- 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
Faculty
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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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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