Form 5471 Categories of Filers: Determining the Proper Category and Filing Requirements

Course Details
- smart_display Format
On-Demand
- signal_cellular_alt Difficulty Level
Intermediate
- work Practice Area
Tax Preparer
- event Date
Monday, August 5, 2024
- schedule Time
1:00 p.m. ET./10:00 a.m. PT
- timer Program Length
110 minutes
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BARBRI is a NASBA CPE sponsor and this 110-minute webinar is accredited for 2.0 CPE credits.
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BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).
This course will explain each category of filer on Form 5471, Information Return of U.S. Persons With Respect to Certain Foreign Corporations. Our knowledgeable international panel will discuss relative and recent legislation, the accompanying Form 5471 schedules that must be filed by category, and the exceptions to the Form 5471 filing requirements and requirements to file specific schedules.
Faculty

Ms. Schmid is a shareholder in the firm. She earned her J.D. from Villanova University School of Law specializing in Corporate Law, and has earned her bachelor’s degree at the University of Pennsylvania where she majored in Political Science and Economics. Ms. Schmid earned her Masters of Law (LL.M.) in Taxation from New York University School of Law. She is a member of the Bar of the Commonwealth of Pennsylvania and the State of New Jersey. Ms. Schmid currently serves as one of the Taxation Law Section’s delegates to the New Jersey State Bar Association General Council. Prior to joining the firm, Ms. Schmid was a Senior Tax Associate at PricewaterhouseCoopers LLP where she specialized in mergers and acquisitions and international tax. While at PwC, Ms. Schmid handled the federal tax implications of complex merger and acquisition transactions involving Fortune 500 corporations. Her experience includes spin-offs, carve outs, liquidations, taxable transactions, and non-recognition transactions. Ms. Schmid’s practice areas include corporate tax, business transactions, real estate, and international tax.

Ms. Diaz Colon specializes in international tax matters including CFC/PFIC rules, cross-border mergers and acquisitions, withholding tax rules, application of tax treaties, and FIRPTA rules. She has experience working with a variety of clients, including partnerships, corporations, individuals, and asset managers.
Description
Form 5471 is one of the most challenging information returns filed by taxpayers. One of the most formidable decisions tax professionals must make is whether or not the return is required. A taxpayer's filing category determines whether a Form 5471 is required and which of the many supporting schedules are needed. An inaccurate decision could be costly since incomplete filings or not filing carries a $10,000 penalty.
This form is continually updated. In addition to the five categories, there are three subcategories to consider in category five. There are exceptions to the filing requirements in each of the five categories as well. Foreign tax advisers need to thoroughly understand the current categories of filers and the corresponding Form 5471 filing obligations of taxpayers with foreign interests.
Listen as our panel of international tax filing experts walks you through determining the appropriate category on Form 5471 for multinational taxpayers.
Outline
- Legislative history
- Form 5471 categories
- Definitions
- Categories 1-5
- Exceptions
- Incomplete or missed filings
- Consequences
- Solutions
Benefits
The panel will review these and other critical issues:
- Identifying category 1-5 filers and the complex attribution rules applicable to each category
- Transactions triggering Category 2 and 3 filing status
- Which specific Form 5471 schedules are needed based on a filer's category
- What Form 5471 exceptions are available, and what are the qualifications for these exceptions?
- What are the potential consequences of incorrect Form 5471 filings?
NASBA Details
Learning Objectives
After completing this course, you will be able to:
- Identify the Form 5471 categories of filers
- Recognize the safe harbors under Rev. Proc. 2019-40
- Determine the filing requirements for the various categories of filers
- Decide when related and unrelated parties may have Form 5471 filing requirements
- Ascertain the penalties for failure to file Form 5471 or deficient filings
- 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.

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