Mastering Form 5472: Filing Requirements for Foreign Individuals, LLCs, and Companies
Meeting Information Return Requirements for Foreign-Owned Disregarded Entities and 25%-Foreign-Owned U.S. Corporations
Note: CLE credit is not offered on this program
Recording of a 110-minute CPE webinar with Q&A
This course will provide tax advisers with a thorough and practical guide to completing Form 5472, focusing on the impact of IRS regulations requiring 5472 reporting by disregarded entities (DREs) with foreign owners. The panel will provide line-by-line guidance on completing the form, define difficult concepts, and discuss the impact of IRS rules expanding filing requirements.
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
Benefits
The panel will discuss these and other important issues:
- What entities and individuals are subject to Form 5472 filing requirements
- Identifying essential elements of IRC 6038A and 6038C to determine definitions of transactions to report
- Line-by-line guidance on completing Form 5472
- Steps that foreign individuals owning DREs operating in the U.S. must take to fulfill filing requirements
- Penalty abatement and mitigation provisions
Faculty

Henry Stow Lovejoy
Counsel
Kostelanetz & Fink
Mr. Lovejoy counsels clients on a full range of tax matters, from planning and structuring transactions to examination... | Read More
Mr. Lovejoy counsels clients on a full range of tax matters, from planning and structuring transactions to examination by and litigation with federal and state tax authorities. He has extensive experience in many areas of the tax law, with particular attention to cross-border investments and transactions and the treatment of financial instruments. Mr. Lovejoy’s current practice focuses on U.S. taxpayers investing and doing business abroad, foreign taxpayers investing in the U.S., and the tax aspects of business contributions.
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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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CPE credit is not available on downloads.
CPE On-Demand