Preparing Form 1120-F for Foreign Corporations: 2020 Revisions, ECI, Protective Claims, and Branch Profits Tax
Recording of a 110-minute CPE webinar with Q&A
This course will provide a practical explanation of completing form 1120-F, U.S. Income Tax Return of a Foreign Corporation. Our foreign tax reporting experts will explain how to properly prepare this onerous form, including who is required to file, filing protective claims, and illustrative examples of the completed form.
- Who should file Form 1120-F
- Entity classifications
- Protective claims
- Simplified procedures for refunds
- IRS campaign
- 2020 revisions
- Pages 2-3, Additional Information
- Trade or business determinations
- Permanent establishment
- Form 5472, Information Return
- Controlled foreign corporations
- Form 8833, Treaty-Based Return Position Disclosure
- Other information disclosures
- Page 4, Effectively Connected Income
- Page 5, Schedule C, Dividends Received Deduction
- Schedule H, Deductions Allocated to ECI
- Schedule I, the Interest Expense Limitation
- Page 5, Schedule J, Tax computation
- Page 6, Branch Profits Tax
- Page 7, Schedule L, Balance Sheet
- 1120-W estimates
- Best practices
The panel will review these and other key issues:
- Who is required to file Form 1120-F, Income Tax Return for Foreign Corporations?
- When should an entity file an 1120-F protective claim, even though not subject to tax and possibly not required to file?
- What methods are used to allocate and apportion ECI and non-ECI expenses on Schedule H?
- What are examples of treaty-based positions that might require filing Form 8833, Treaty-Based Return Position Disclosure?
- What recent changes have been made to the 1120-F?
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
Ms. Dougherty specializes in U.S. international tax reporting, compliance, consulting, planning, and structuring as a significant contributor to the firm’s international tax practice. She has extensive experience assisting clients with U.S. tax reporting and compliance for offshore assets and foreign accounts. Ms. Dougherty provides outbound U.S. international tax guidance to U.S. individuals and businesses with activities in other countries. She also provides inbound U.S. international tax guidance to nonresident individuals and businesses with activities in the U.S. Ms. Dougherty has counseled U.S. taxpayers regarding the outbound formation, capitalization, acquisition, operation, reorganization, and liquidation of foreign companies. She has significant experience with U.S. federal nonresident tax withholding, foreign partner tax withholding, and FIRPTA withholding. She works closely with nonresident individuals and businesses regarding inbound U.S. real property investment. Additionally, Ms. Dougherty has assisted U.S. taxpayers with IRS amnesty program disclosures of offshore assets and foreign accounts.Close
Mr. Gifford serves in the firm's International Corporate Services Practice. He focuses on working primarily with... | Read More
Mr. Gifford serves in the firm's International Corporate Services Practice. He focuses on working primarily with U.S. and foreign-owned multinational corporate clients with either U.S. inbound or outbound activities. Mr. Gifford is experienced in complex structuring planning, provision preparation assistance and review, and tax compliance preparation for companies in the communications, financial services, and defense contractor industries. He is a frequent author and speaker on tax issues.Close
Kimberlee S. Phelan, CPA, MBA
Ms. Phelan has more than 15 years of tax and accounting experience at national and regional accounting firms. Her... | Read More
Ms. Phelan has more than 15 years of tax and accounting experience at national and regional accounting firms. Her work emphasizes inbound and outbound international structuring, corporate tax research and planning, individual tax and executive compensation planning.Close
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