Mastering Subpart F Tax Compliance: Key Reporting Requirements on Forms 5471 and 1118

Recording of a 90-minute premium CLE/CPE video webinar with Q&A

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Conducted on Tuesday, August 23, 2022

Recorded event now available

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Course Materials

This CLE/CPE course will provide tax professionals with an in-depth discussion of reporting Subpart F income challenges. The panel will discuss the proper methods of determining the Subpart F income earned by U.S. persons that qualify as U.S. shareholders of controlled foreign corporations (CFCs) and how to report such Subpart F income. The panel will assist tax pros in navigating Forms 5471 and 1118 and discuss tax planning techniques to minimize tax liability and penalties.

Description

The Subpart F rules require U.S. shareholders of CFCs to treat certain types of foreign corporate income as taxable in the current year. The Subpart F rules increase the number of foreign corporations treated as CFCs and catch many more U.S. persons in the Subpart F net. Tax professionals must recognize the resulting U.S. foreign tax information reporting challenges for U.S. persons owning foreign corporations. Advisers need to expand their Subpart F expertise to navigate the two most relevant Subpart F reporting platforms: Form 5471 and Form 1118.

The panel will also compare Subpart F with the GILTI anti-deferral regime. Due to the GILTI anti-deferral regime, a U.S. shareholder of a CFC may even wish to trigger Subpart F income to get out of the GILTI rules because Subpart F income is subject to less stringent U.S. foreign tax credit strictures than GILTI.

Listen as our panel discusses Subpart F rules and provides a practical guide to determining CFC ownership, Subpart F income, and reporting obligations for U.S. shareholders of CFCs with Subpart F income.

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Outline

  1. Basic components of the Subpart F anti-deferral regime
  2. Determining Subpart F income
  3. Reporting Subpart F income on Form 5471
  4. Claiming the foreign tax credit for Subpart F income on Form 1118
  5. Best practices for ensuring accurate reporting of Subpart F income
  6. Analyzing the high-tax election for subpart F and GILTI vs. foreign tax credits

Benefits

The panel will review these and other key issues:

  • What are the tax compliance challenges for U.S. persons post-2017 TCJA?
  • What are the challenges in determining and calculating Subpart F income?
  • What are the main issues and pitfalls to avoid in preparing Forms 5471 and 1118?

Faculty

Chesman, Adam
Adam Chesman

Senior Director, International M&A Tax Services
RSM US

Mr. Chesman has broad experience in federal, state, and international taxation, including consulting, compliance, and...  |  Read More

Duskis, Ayelet
Ayelet Duskis

Director
Eisner Advisory Group

Ms. Duskis is a Tax Senior Manager and member of the Financial Services Group, with more than 10 years of experience in...  |  Read More

Mainguy, Bradley
Bradley Mainguy, JD, LLM

Senior Manager
CohnReznick

Mr. Mainguy has more than eight years of public accounting experience providing international tax services to clients...  |  Read More

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