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
A live 110-minute CPE webinar with interactive 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 complex 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 vital 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
Heather K.P. Fincher
Attorney
Kostelanetz
Ms. Fincher advises multinational businesses and high-net-worth individuals on US federal income tax matters, with a... | Read More
Ms. Fincher advises multinational businesses and high-net-worth individuals on US federal income tax matters, with a particular focus on international tax planning and controversies. She counsels both US- and foreign-owned businesses and individuals regarding the US tax consequences of cross-border investments, cryptocurrency issues, mergers and acquisitions, joint ventures and restructurings. Ms. Fincher also regularly advises clients on special issues arising in international tax controversies.
Close
Robert Russell
Senior Counsel
Taylor Nelson Amitrano
Mr. Russell is Senior Counsel with Taylor Nelson Amitrano, LLP joining the firm in 2024... | Read More
Mr. Russell is Senior Counsel with Taylor Nelson Amitrano, LLP joining the firm in 2024 where he represents clients in federal and state tax examinations, appeals and litigation. He developed an expertise in government enforcement and tax policy while serving in prior government roles with the Internal Revenue Service, Department of Treasury and the U.S. Congress’ Joint Committee on Taxation. Prior to joining the firm, Mr. Russell worked at a large law firm in Orange County and a boutique tax litigation firm in Washington, D.C. where he focused on tax controversy and tax consulting matters. He has extensive experience in international tax matters for both U.S. businesses and individuals operating overseas and foreign investment into the U.S.
Close
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.
CloseEarly Discount (through 07/11/25)
CPE credit processing is available for an additional fee of $39.
CPE processing must be ordered prior to the event.
See
NASBA details.
Cannot Attend August 4?
Early Discount (through 07/11/25)
CPE credit is not available on downloads.
CPE On-Demand