Forms 5471 and 5472: Meeting the Substantially Complete Standards
Note: CLE credit is not offered on this program
Recording of a 110-minute CPE webinar with Q&A
This course will discuss best practices for meeting the substantially complete standard for international reporting required for Forms 5471 and 5472 and as applied to other required foreign information returns.
Outline
- Statutory provisions of IRC 6038A and 6038C
- Key definitions under statutory provisions and regulations
- Reporting corporations
- Reportable transactions
- Related parties
- Regulations (TD 9796) requiring foreign-owned DREs to file Form 5472
- Completing the form
- Penalties and penalty abatement provisions
- Impact of Farhy v. Commissioner on foreign reporting penalties
- Potential Claims for Refund
Benefits
The panel will review these and other critical issues:
- What foreign reporting deficiencies are considered substantially incomplete?
- What forms, in addition to Forms 5471 and 5472, are subject to substantial compliance requirements?
- What are the best steps to take toward penalty abatement for incomplete submissions?
- How are omission oversights best handled or corrected?
Faculty
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
Mr. Samtoy’s practice specializes in international tax compliance and consulting services, with a focus on individuals, closely-held businesses, and hedge funds. He has particular expertise in structuring and reporting foreign manufacturing arrangements and foreign holding companies, and is experienced in foreign asset disclosure requirements, as well as foreign trust and estate reporting.
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Michael Sardar
Partner
Kostelanetz
Mr. Sardar has extensive experience on a wide range of tax controversy and white collar criminal defense matters. He... | Read More
Mr. Sardar has extensive experience on a wide range of tax controversy and white collar criminal defense matters. He represents clients in all stages of civil and criminal tax controversies before the Internal Revenue Service (IRS), state tax authorities, the Department of Justice, and local prosecutors. Mr. Sardar also represents and advises taxpayers facing audits and investigations of noncompliance with IRS foreign bank and asset reporting requirements, utilizing his skill, creative thinking, and deep knowledge of the law in this area. He also has a great deal of experience representing corporate and individual taxpayers making voluntary disclosures of unreported income to the IRS and state tax authorities. Mr. Sardar has also represented scores of clients with unreported foreign assets, enabling the repatriation of over half a billion dollars of offshore assets through the IRS Offshore Voluntary Disclosure Program, the Streamlined Compliance Procedures, and the IRS’ current Voluntary Disclosure Practice.
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CPE credit is not available on downloads.
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