Form 5471 Schedule J, Accumulated Earnings of Controlled Foreign Corporations: Line-by-Line
Deep Dive Into Additional Categories, Classifications, and Sections of Complex Schedule J
Note: CLE credit is not offered on this program
Recording of a 110-minute CPE webinar with Q&A
This course will provide tax advisers with a practical, in-depth guide to completing Form 5471's recently revised Schedule J, Accumulated Earnings & Profits (E&P) of Controlled Foreign Corporations. The panel will take a line-by-line approach to the form, discussing each of the income items listed in the various sub-sections of IRC 959, and detail how to identify the Nonpreviously Taxed E&P Subject to Recapture as Subpart F Income required in Part II. This is an advanced level webinar for attendees well versed in prior revisions of Form 5471.
Outline
- Prior versions of Schedule J
- Seven (7) lines of calculations
- Five (5) columns of income/E&P classifications
- All references to post-1986 balances and carry-forward amounts
- Income classifications in revised Schedule J
- Calculation questions
- Part II Nonpreviously Taxed E&P Subject to Recapture as Subpart F Income (Section 952(c)(2))
Benefits
The panel will discuss these and other specific changes to Schedule J:
- Lines and columns required to report accumulated E&P balances concerning categories of previously taxed E&P necessitated by income inclusions under Section 965(a) and GILTI
- How this schedule incorporates Subpart F inclusions and recaptures
- How to handle deficit calculations after nonrecognition transactions
- Reclassification lines
- Changes made to Schedule J for the current year
Faculty
Anthony V. Diosdi
Partner
Diosdi Ching & Liu
Mr. Diosdi is an experienced trial lawyer who regularly defends individuals and corporations in matters involving tax... | Read More
Mr. Diosdi is an experienced trial lawyer who regularly defends individuals and corporations in matters involving tax controversies and government regulatory enforcement. He also has vast experience assisting clients who find themselves with unreported or undeclared bank accounts outside the U.S. Mr. Diosdi is acknowledged as one of the nation’s leading experts in contesting penalties associated with failing to file FBARs. In addition to representing clients in tax controversy matters, he advises clients on U.S. international tax matters, including tax planning with respect to their structures and transactions. In particular, Mr. Diosdi has experience advising on issues relating to tax treaties, pre-immigration planning for foreigners moving to the U.S., expatriation planning, tax planning for foreign companies doing business in the U.S., and subpart F income minimization. More recently, he has focused on helping clients navigate U.S. tax reform, including the regimes for Global Intangible Low-Taxed Income and Foreign-Derived Intangible Income, and the new limitations on foreign tax credits.
Close
Alison N. Dougherty, CPA
Managing Member
Googolplex Tax
Ms. Dougherty provides U.S. tax reporting, compliance, consulting, planning, and structuring solutions to U.S. and... | Read More
Ms. Dougherty provides U.S. tax reporting, compliance, consulting, planning, and structuring solutions to U.S. and foreign corporations, partnerships, LLCs, individuals, and trusts. She specializes in U.S. international tax reporting and compliance with the preparation and review of the U.S. federal Forms 5471, 926, 8992, 8993, 5472, 8865, 8858, 8621, 8804, 8805, Schedules K-2 and K-3, 1116, 1118, 1042, 1042-T, 1042-S, 8832, 8833, 2555, 3520, 3520-A, 5713, 1120-F, 1040-NR, 8288, 8288-A, 8288-B, 8233, 8840, 8843, 8854, 8938, and FBAR. Ms. Dougherty has extensive experience working with U.S. businesses and individuals with outbound activities in foreign countries. She has also worked with foreign companies and nonresident individuals with inbound activities in the United States. Ms. Dougherty has significant experience with U.S. nonresident withholding tax, foreign partnership withholding tax, and FIRPTA withholding tax. She has managed U.S. tax compliance and advisory client engagements for U.S. C corporations, S corporations, partnerships, LLCs, U.S. individuals, U.S. trusts, foreign corporations, foreign partnerships, foreign LLCs, nonresident individuals, and foreign trusts.
Ms. Dougherty is a CPA and a tax attorney with more than 15 years of combined experience in public accounting, the practice of law, and corporate industry. She was previously a tax partner in a large regional public accounting firm in the Washington, DC area. Ms. Dougherty has served clients in various industries including technology, U.S. government contracting, commercial services, telecommunications, real estate, investment partnerships, commodities, high net worth individuals, and family offices. She has also served as a technical resource to other CPAs, accountants, tax professionals, public accounting firms, attorneys, and law firms.
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