Mastering Form 5471 for Interests in Foreign Entities: Determining Ownership Share and Correct Filing Status

Tax Reform Definitions of U.S. Shareholder Create New Filing Obligations

This program has been cancelled

A live 110-minute CPE webinar with interactive Q&A

Monday, December 31, 2018

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

This webinar will provide tax return preparers with a thorough and practical guide to completing Form 5471 Information Return of U.S. Persons With Respect to Certain Foreign Corporations. The panel will explain approaches for correctly identifying taxpayer categories, discuss common challenges and areas of deficiency in Form 5471 completion, and detail the specific changes passed in the recent tax reform bill that may create additional reporting obligations for U.S. taxpayers owning shares of foreign corporations.


Form 5471 Information Return of U.S. Persons With Respect to Certain Foreign Corporations is one of the most complex reporting obligations in the U.S. offshore information tax reporting regime. 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. The law alters the definition of U.S. shareholder for purposes of information-filing duties, and some taxpayers will face new disclosure obligations for their foreign-sourced assets.

Listen as our panel of veteran advisers identifies and explains the more difficult 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
    1. Schedules
    2. Difficult compliance issues
  5. 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
  • Master reporting financial and operational information needed to complete the form
  • Grasp U.S. international tax reporting rules and obligations of U.S. persons with interests in foreign corporations
  • Avoid audit red flags and common errors that the Service looks for when reviewing Form 5471


Samtoy, John
John Samtoy

Tax Principal
Holthouse Carlin & Van Trigt

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

Additional faculty
to be announced.