Offshore Ownership Structures: Lessons Learned Under Tough IRS Scrutiny

Complying With Foreign Information Reporting Forms 5471, 5472, 1120F and 926

Note: CLE credit is not offered on this program

Recording of a 110-minute CPE webinar with Q&A

Conducted on Tuesday, July 2, 2019

Recorded event now available

or call 1-800-926-7926
Course Materials

This course will prepare corporate tax executives and advisers with a useful survey of the reporting requirements for U.S. companies with cross-border structures. The panel will outline the significant changes and challenges to completing Forms 5471, 5472, 1120-F and 926 with practical experiences geared toward improving compliance. The panel will provide insights to deal with IRS policies on audits and penalties.


U.S. taxpayers have long faced challenges with timely and accurately filing IRS forms disclosing corporate foreign ownership structures. The different forms required include 1120-F (foreign entities) and 926 (foreign asset transfers) and changed Forms 5471 and 5472 (shares in foreign companies). The massive changes to U.S. tax treatment of foreign holdings have required tax advisers to evaluate their clients' cross-border business entity structures to comply with the new rules.

The passage of the 2017 tax reform law has necessitated changes to virtually every foreign-related tax information form, ranging from minor "tweaks" to major overhauls. In the near term, at least, the new rules and resulting compliance complexities have only increased the data collection and reporting demands on corporate tax professionals. Meanwhile, U.S. companies are grappling with IRS audit emphasis on foreign business structures and face costly penalties and interest, and branch profits tax, for mistaken or late disclosures.

Improve your client's or company's compliance: Learn from the real world experiences of tax advisers familiar with data demands from Forms 1120-F, 926, 5471 and 5472, and who are veterans in dealing with IRS oversight of foreign ownership structures.

Listen as our panel of seasoned advisers provides a useful overview of the IRS' evolving requirements for reporting on foreign ownership.



  1. IRS enforcement and audit environment to date
  2. Mechanics and overview of foreign information reporting requirements
  3. Form changes and new reporting requirements brought about by 2017 tax reform law
    1. Forms 5471 and 5472 compliance issues
    2. GILTI
    3. Form 926
    4. Form 1120-F
  4. IRS enforcement and audit environment to date
    1. Background on stricter Form 5471 penalties and frequency with which they've been imposed
    2. The penalty structure for Forms 5472, 1120-F and 926; recent audit activity
    3. New foreign compliance campaigns
    4. Expiration of OVDP and replacement voluntary compliance programs
  5. Form changes and new reporting requirements brought about by 2017 tax reform law
    1. Forms 5471 and 5472 compliance issues
    2. GILTI
    3. Form 926
    4. Form 1120-F


The panel will prepare you for these and other crucial aspects:

  • Understanding--and taking--the preventive steps to avoid costly penalties and interest, branch profits tax assessments, audits, and other adverse events
  • Planning for an IRS audit of foreign ownership connections based on enforcement activities to date
  • Mastering the details regarding the value, costs and gains on transferred assets, direct and indirect expense allocations, and other disclosures required on forms 5471, 5472, 1120-F and 926


Dougherty, Alison
Alison N. Dougherty, J.D., LL.M., CPA


Ms. Dougherty specializes in U.S. international tax reporting, compliance, consulting, planning, and structuring as a...  |  Read More

Samtoy, John
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

Access Anytime, Anywhere

CPE credit is not available on downloads.