Mastering Form 5472: New Filing Requirements for Foreign Individuals, LLCs, and Companies

Meeting Information Return Requirements for Foreign-Owned Corporations, Disregarded Entities and 25%-Foreign-Owned U.S. Corporations

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


Wednesday, May 24, 2017 (Tomorrow)
1:00pm-2:50pm EDT, 10:00am-11:50am PDT


This webinar will provide tax advisers with a thorough and practical guide to completing Form 5472, focusing on the impact of new IRS regulations requiring 5472 reporting by foreign owners of disregarded entities (DREs). The panel will provide line-by-line guidance to completing the form, defining key concepts and discussing the impact of recent IRS rules expanding filing requirements.

Description

Form 5472, “Information Return of a 25% Foreign-Owned U.S. Corporation or a Foreign Corporation Engaged in a U.S. Trade or Business,” is one of the most complicated forms applicable to foreign companies. Originally, the reporting obligations applied to corporations only; however, IRS announced changes in 2016 that extends the reach of Form 5472 requirements to non-U.S. individuals owning DREs active in the U.S.

IRC 6038 requires “reporting corporations” to disclose specified “reportable transactions” they have with any “related parties” on Form 5472. The definition of each element is highly complex, and tax advisers must have a thorough grasp of these definitions to ensure that the taxpayer has met the record maintenance requirements to support its tax position for these transactions.

In Dec. 2016, Treasury regulations expanded the scope of the filing requirements. In response to foreign individuals’ use of DREs to avoid information reporting, the Service now requires foreign-owned single member LLCs and other DREs to file Form 5472. Foreign persons who own a single-member domestic DRE, either directly or indirectly through attribution rules, must obtain an taxpayer identification number and disclose reportable transactions. Penalties for failing to file Form 5472 may reach $10,000 per failure, with complicated rules for penalty mitigation.

Listen as our experienced panel provides a thorough and practical guide to completing Form 5472, including key definitions and a discussion of the expanded filing requirements.

Outline

  1. Statutory provisions of IRC 6038A and 6038C
  2. Key definitions
    1. Reporting corporations
    2. Reportable transactions
    3. Related parties
  3. New regulations (TD 9796) requiring foreign-owned DREs to file Form 5472
  4. Completing the form
  5. 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 key elements of IRC 6038A and 6038C to determine definitions of transactions that must be reported
  • 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

Learning Objectives

After completing this course, you will be able to:

  • Identify entities and individuals who must file Form 5472
  • Recognize reportable transactions with related parties that must be disclosed on Form 5472
  • Determine the steps foreign persons owning DREs must take to disclose reportable transactions
  • Discern available exemptions and penalty mitigation provisions

Faculty

Alison N. Dougherty, J.D., LL.M., Director
Aronson, Rockville, Md.

Ms. Dougherty has extensive experience assisting clients with U.S. tax reporting and compliance for offshore assets and foreign accounts. She specializes in international tax compliance, planning and structuring as a subject matter leader of her firm's international tax practice. Her responsibilities include U.S. Federal and multi-state tax compliance for C corporations, S corporations, partnerships and individuals. She also provides transactional tax planning and structuring services.

Kirsten Burmester, Member
Caplin & Drysdale, Washington, D.C.

Ms. Burmester's practice focuses on international tax issues, including both planning and controversy work. She has extensive experience advising high net worth individuals on international taxation issues, including advising foreign individuals on structuring investments into the U.S., and advising U.S. individuals on the U.S. tax implications of offshore investment and estate planning structures. She advises businesses on international taxation issues.


Registration per Person for Live Event

Additional lines for this conference can be purchased at 25% off. For orders of five or more lines, further discounts will apply and will be automatically reflected in the cart.

Live Webinar $147.00

Live Webinar & CPE Processing $182.00


CPE per Person on Live Event

Continuing Professional Education credit processing is available for an additional fee. CPE processing must be ordered prior to the event. To qualify for CPE you may not listen via the telephone.

This program is eligible for 2.0 CPE credits.

  • Field of Study: Taxes.
  • Level of Knowledge: Intermediate.
  • Advance Preparation: None.
  • Teaching Method: Seminar/Lecture.
  • Delivery Method: Group-Internet (via computer).
  • Attendance Monitoring Method: Attendance is monitored electronically via a participant's PIN and through a series of verification codes announced throughout the presentation.
  • Prerequisite: Three years+ business or public firm experience at mid-level within the organization, preparing complex tax forms and schedules; supervisory authority over other preparers/accountants. Specific knowledge and understanding of information reporting rules for foreign companies and individuals engaged in business activities in the U.S.; familiarity with Form 5472 (Information Return of Foreign Corporation Engaged in U.S. Trade or Business)..

NOTE: CPE credit processing for all attendees must be ordered by 2pm Eastern the day of the program to receive a Certificate of Attendance within 24 hours.


Recordings

CPE On-Demand

Includes video streaming of full program plus handouts (available within a week of the live webinar).

Strafford is a NASBA-approved CPE provider for On-Demand webinars.

This program is eligible for 2.0 CPE credits.

  • Field of Study: Taxes.
  • Level of Knowledge: Intermediate.
  • Advance Preparation: Printing and reviewing Program Outlines and materials.
  • Teaching Method: Seminar/Lecture.
  • Delivery Method: QAS Self-Study.
  • Prerequisite: Three years+ business or public firm experience at mid-level within the organization, preparing complex tax forms and schedules; supervisory authority over other preparers/accountants. Specific knowledge and understanding of information reporting rules for foreign companies and individuals engaged in business activities in the U.S.; familiarity with Form 5472 (Information Return of Foreign Corporation Engaged in U.S. Trade or Business)..

On-Demand Webinar & CPE Processing $182.00


Recorded Event

Includes full event recording plus handouts (available after live webinar).

Note: Self-study CPE and EA credits are not offered on recorded events.

Recorded Webinar Download $147.00
Available 48 hours after the live event

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Recorded Audio Download (MP3) $147.00
Available 24 hours after the live event

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DVD (Slide Presentation with Audio) $147.00 plus $9.45 S&H
Available ten business days after the live event

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Registration Plus Recorded Event

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Live Webinar & Webinar Download $194.00

Recorded Webinar Download Only $47.00 with Registration/Webinar Combo

Live Webinar & Audio Download $194.00

Recorded Audio Download (MP3) Only $47.00 with Registration/MP3 Combo

Live Webinar & DVD $194.00 plus $9.45 S&H

DVD (Slide Presentation with Audio) Only $47.00 with Registration/DVD Combo


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IRS Approved Provider

Strafford is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).

Program Materials

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Program Materials

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EA Credit

Strafford is an IRS approved continuing education provider and this course is approved for 2 enrolled agent (EA) credit hours.

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