Strafford Webinar: Form 5471 for Interests in Foreign Entities After Tax Reform

New Schedules, Determining Ownership Share and Correct Filing Status

June 12, 2019
John Samtoy, International Tax Principal

Form 5471 Information Return of U.S. Persons With Respect to Certain Foreign Corporations has long been one of the most complex reporting obligations in the U.S. offshore information tax reporting regime, and the 2017 legislation created additional challenges, increasing both the amount of information required and the number of U.S. taxpayers obligated to file. Failure to file a "substantially complete" Form 5471, absent reasonable cause, exposes the taxpayer to severe monetary and other penalties, beginning at $10,000 per year per missed form.

Filing Form 5471 requires data reporting from simple to highly intricate. Correctly completing the form involves hours of intensive work, including proper recordkeeping and data analysis. U.S. individuals and entities that own, acquire or dispose of shares of a foreign corporation may be required to file Form 5471 with their income tax returns. U.S. officers and directors of these foreign corporations may also have reporting responsibility.

Foreign corporation attribution rule changes under tax reform further complicate compliance. The law alters the definition of U.S. shareholder for purposes of information-filing duties, and some taxpayers will face new disclosure obligations for their foreign-sourced assets.

Listen as our panel of veteran advisers identifies and explains the more difficult aspects of preparing Form 5471 for U.S. owned foreign corporations. The panel will outline approaches to help you accurately identify taxpayer reporting categories, determine relevant direct, indirect and constructive ownership interests, identify common compliance mistakes, and stay ahead of IRS examination issues.

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