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  • schedule 110 minutes

Form 5471 Schedule J, Accumulated Earnings of Controlled Foreign Corporations: Line-by-Line

Deep Dive Into Categories, Classifications, and Sections of Complex Schedule J

$197.00

This course is $0 with these passes:

CPE
ALL
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Description

The complexity and compliance burden of virtually all foreign tax information reporting continues to escalate. Multiple provisions in the law increased the calculation, payment, and reporting obligations on U.S. taxpayers with foreign income or assets and foreign taxpayers with activities subject to U.S. tax jurisdiction. These forms continue to be updated and modified annually.

Form 5471 continues to be one of the most complicated reporting obligations in the U.S. offshore information tax reporting regime, notably Schedule J, Accumulated Earnings and Profits (E&P) of Controlled Foreign Corporations. However, the deemed repatriation provisions necessitated a modification of Schedule J, involving a longer and significantly more complicated set of calculations.

Schedule J contains additional categories of accumulated E&P with requirements to calculate and disclose reclassifications within various sub-sections of IRC 959. The Schedule also contains an additional part and several new columns requiring taxpayers to report current and recaptured Subpart F income. These calculations create additional burdens to an already complex form.

Listen as our panel of veteran advisers provides an in-depth, line-by-line, and column-by-column guide to the changes tax reform made to completing Schedule J.

Presented By

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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Alex McGowin
International Tax Accountant
McGowin Tax, LLC

Mr. McGowin is a trusted advisor to multinational individuals and businesses seeking to optimize their global tax position and stay in compliance.

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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).

Date + Time

  • event

    Tuesday, April 22, 2025

  • schedule

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

  1. Form 5471 Schedule J: introduction
  2. Categories of filers
  3. Part I - Accumulated E&P of CFCs
  4. Part II - Nonpreviously taxed E&P subject to recapture as Subpart F income

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

Learning Objectives

After completing this course, you will be able to:

  • List the specific additional categories, calculations, and classifications of Form 5471 Schedule J
  • Recognize the rules for reclassifications under Sections 959(c)(1) and 959(c)(2)
  • Determine calculations of E&P "hovering deficit" after nonrecognition transaction carryover (Lines 5a, 5b, and 13)
  • Discern how to calculate the Subpart F income inclusions and Subpart F Recapture
  • 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 at mid-level within the organization, preparing complex tax forms and schedules; supervisory authority over other preparers/accountants. Specific knowledge and understanding of Form 5471 (Information Return of U.S. Persons With Respect to Certain Foreign Corporations); familiarity with the 5471 IRS penalty structure and key U.S. international tax reporting rules and obligations of U.S. presons with interests in foreign corporations. This is an advanced-level webinar for attendees well-versed in prior revisions of Form 5471.

BARBRI 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

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

BARBRI CE webinars-powered by Strafford-are backed by our 100% unconditional money-back guarantee: If you are not satisfied with any of our products, simply let us know and get a full refund. Contact us at 1-800-926-7926 .