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Course Details

Course Information
  • smart_display Format

    On-Demand

  • signal_cellular_alt Difficulty Level

    Intermediate

  • work Practice Area

    Tax Preparer

Date & Time
  • event Date

    Thursday, June 13, 2024

  • schedule Time

    1:00 p.m. ET./10:00 a.m. PT

  • timer Program Length

    110 minutes

Credit Information

  • BARBRI is a NASBA CPE sponsor and this 110-minute webinar is accredited for 2.0 CPE credits.

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

$197.00
CPE
ALL

This course will explain the attribution rules for stock ownership for individuals and entities and the filing requirements of Form 5471. Our panel of international tax experts will discuss determining direct and indirect stock ownership that can result in unexpected filing obligations.

Faculty

Anthony V. Diosdi
Partner
Diosdi & Liu, LLP

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.

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Kerrin N.T. Liu
Partner
Diosdi & Liu, LLP

Ms. Liu focuses on civil tax litigation, representation before Internal Revenue Service Criminal Investigations, domestic tax compliance, and international tax compliance. She has represented clients as second chair in trials before the United States Tax Court.  Kerrin also handled Internal Revenue Service, State of California, and FBI criminal investigation cases involving individuals and business entities. In addition, Ms. Liu has assisted clients in a broad range of tax resolution cases.

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Description

Family attribution and constructive ownership determinations are complex. IRC Section 6038 and the related regulations require reporting specific information about foreign corporations and partnerships. Filing Form 5471, Information Return of U.S. Persons With Respect to Certain Foreign Corporations, can satisfy these requirements. Not filing can generate an initial penalty of $10,000 that can rise to a maximum of $50,000 per unfiled form. Individuals without direct stock ownership, or less than 10 percent, could still have a filing obligation through attribution rules.

Revenue Procedure 2019-40 provides some relief by providing three safe harbors. However, this relief is generally limited to U.S. shareholders of foreign-controlled CFCs subject to reporting requirements after repealing Section 958(b)(4).

Listen as our panel of foreign tax reporting veterans defines complex terminology, provides examples of common attribution scenarios, and assists tax practitioners in determining filing requirements and the category of filers for Form 5471. International tax practitioners must understand how direct and indirect stock ownership is determined and reported on Form 5471.

Outline

  1. Form 5471 attribution rules: an overview
    1. Safe harbor rules under Revenue Procedure 2019-40
    2. Defining CFCs, U.S. shareholders, and U.S. persons
  2. IRC Section 958
    1. Direct and indirect stock ownership
    2. Unrelated and related shareholders
  3. Category of filers
  4. Attribution examples
  5. Applicable penalties
  6. New Schedule R

Benefits

The panel will review these and other critical issues:

  • Examining the new Form 5471 categories of filers
  • Qualifying for the safe harbors under Revenue Procedure 2019-40
  • Applying the Section 318(a) family attribution rules for Category 4 filers
  • Determine filing requirements for categories of filers
  • Decide when related and unrelated parties may have 5471 filing requirements
  • Filing New Schedule R for distributions from foreign corporations

NASBA Details

Learning Objectives

After completing this course, you will be able to:

  • Ascertain when certain unrelated parties may be required to file Form 5471
  • Decide when taxpayers may be eligible for safe harbor relief under Rev Proc 2019-40
  • Identify U.S. persons subject to Form 5471 filing requirements
  • Determine filing obligations by categories of filers

  • 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 attendance verification prompts displayed throughout the program
  • Prerequisite: Three years+ business or public firm experience preparing complex tax forms and schedules, supervising other preparers or accountants. Specific knowledge and understanding of international taxation including residency determination, foreign entity classifications, application of treaty benefits, as well as GILTI, Subpart F, and the related Section 250 deductions.

Strafford Publications, Inc. is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of Accountancy have final authority on the acceptance of individual courses for CPE Credits. Complaints regarding registered sponsons may be submitted to NASBA through its website: www.nasbaregistry.org.

IRS Approved Provider

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