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Home » Webinars » Mastering Form 5472: Filing Requirements for Foreign
Individuals, LLCs, and Companies
MASTERING FORM 5472: FILING REQUIREMENTS FOR FOREIGN INDIVIDUALS, LLCS, AND
COMPANIES
MEETING INFORMATION RETURN REQUIREMENTS FOR FOREIGN-OWNED DISREGARDED ENTITIES
AND 25%-FOREIGN-OWNED U.S. CORPORATIONS
Note: CLE credit is not offered on this program
A live 110-minute CPE webinar with interactive Q&A
This program is included with the Strafford CPE Pass. Click for more
information.
This program is included with the Strafford CPE+ Pass. Click for more
information.
This program is included with the Strafford All-Access Pass. Click for more
information.
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Tuesday, August 22, 2023
1:00pm-2:50pm EDT, 10:00am-11:50am PDT
or call 1-800-926-7926
Add to your calendar
--------------------------------------------------------------------------------
This course will provide tax advisers with a thorough and practical guide to
completing Form 5472, focusing on the impact of IRS regulations requiring 5472
reporting by disregarded entities (DREs) with foreign owners. The panel will
provide line-by-line guidance on completing the form, define complex concepts,
and discuss the impact of IRS rules expanding filing requirements.
DESCRIPTION
Form 5472, Information Return of a 25% Foreign-Owned U.S. Corporation or a
Foreign Corporation Engaged in a U.S. Trade or Business, is one of the most
complicated forms of all U.S. filing requirements concerning foreign persons.
Initially, the reporting obligations applied to corporations only; now, the
requirements extend to DREs active in the U.S. owned by non-U.S. individuals and
corporations.
IRC 6038A, IRC 6038C, and the regulations require a reporting corporation to
disclose specified reportable transactions with any "related parties" on Form
5472. Defining these elements is highly sophisticated, so tax advisers must have
a thorough grasp of each aspect to ensure that the taxpayer has disclosed all
reportable transactions and met the record maintenance requirements to support
its tax position for these transactions.
In response to scenarios in which foreign individuals and corporations were
conducting business in the U.S. through DREs to avoid information reporting, the
Service now requires foreign-owned single-member LLCs and other DREs to file
Form 5472.
Through attribution rules, foreign persons owning a U.S. domestic DRE, either
directly or indirectly, must obtain necessary taxpayer-identification numbers
and disclose reportable transactions. Penalties for failing to file Form 5472
are $25,000 per failure, with complicated rules for penalty mitigation.
Listen as our experienced panel provides a thorough and practical guide to
completing Form 5472, including key definitions and discussing the expanded
filing requirements.
READ MORE
OUTLINE
1. Statutory provisions of IRC 6038A and 6038C
2. Key definitions under statutory provisions and regulations
1. Reporting corporations
2. Reportable transactions
3. Related parties
3. Regulations (TD 9796) requiring foreign-owned DREs to file Form 5472
4. Corporate Transparency Act
5. Completing the form
6. Penalties and penalty abatement provisions
BENEFITS
The panel will discuss these and other vital issues:
* What entities and individuals are subject to Form 5472 filing requirements?
* Identifying essential elements of IRC 6038A and 6038C to determine
definitions of transactions to report
* Line-by-line guidance on completing Form 5472
* Steps that foreign individuals owning DREs operating in the U.S. must take to
fulfill filing requirements
* Penalty abatement and mitigation provisions
FACULTY
Heather K.P. Fincher
Attorney
Kostelanetz
Ms. Fincher advises multinational businesses and high-net-worth individuals on
US federal income tax matters, with a... | Read More
Ms. Fincher advises multinational businesses and high-net-worth individuals on
US federal income tax matters, with a particular focus on international tax
planning and controversies. She counsels both US- and foreign-owned businesses
and individuals regarding the US tax consequences of cross-border investments,
cryptocurrency issues, mergers and acquisitions, joint ventures and
restructurings. Ms. Fincher also regularly advises clients on special issues
arising in international tax controversies.
Close
Robert Russell
Senior Counsel
Rutan & Tucker
Mr. Russell represents businesses and individuals in a wide-range of tax
matters. He provides tax planning, tax... | Read More
Mr. Russell represents businesses and individuals in a wide-range of tax
matters. He provides tax planning, tax controversy and transactional tax
services with a specialty on cross-border tax issues.
Close
John Samtoy
Tax Partner
Holthouse Carlin & Van Trigt
Mr. Samtoy’s practice specializes in international tax compliance and consulting
services, with a focus on... | Read More
Mr. Samtoy’s practice specializes in international tax compliance and consulting
services, with a focus on individuals, closely-held businesses, and hedge funds.
He has particular expertise in structuring and reporting foreign manufacturing
arrangements and foreign holding companies, and is experienced in foreign asset
disclosure requirements, as well as foreign trust and estate reporting.
Close
Attend on August 22
Register + Buy CPE Processing $236
CPE credit processing is available for an additional fee of $39.
CPE processing must be ordered prior to the event. See NASBA details.
NASBA Details
This program is eligible for 2.0 CPE credits.
Learning Objectives
After completing this course, you will be able to:
* Establish which entities must file Form 5472
* Recognize reportable transactions with related parties that must be reported
on Form 5472
* Determine the regulations' impact on DREs and whether a disregarded entity
will be treated as a corporation for Form 5472 filing purposes
* Ascertain applicable penalties for failure to file Form 5472 or maintain
records
* Identify available exemptions and penalty abatement provisions for failure to
file Form 5472 or maintain records
* Recognize the steps that foreign individuals owning DREs operating in the
U.S. must take to fulfill filing requirements
* 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
that are 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 information reporting rules for foreign companies and
individuals engaged in business activities in the U.S.; familiarity with Form
5472 (Information Return of Foreign Corporation Engaged in U.S. Trade or
Business)..
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 credit.
Complaints regarding registered sponsors may be submitted to the National
Registry of CPE Sponsors 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).
CANNOT ATTEND AUGUST 22?
CPE credit is not available on downloads.
CPE On-Demand
See NASBA details.
NASBA Details
This program is eligible for 2.0 CPE credits.
Learning Objectives
After completing this course, you will be able to:
* Establish which entities must file Form 5472
* Recognize reportable transactions with related parties that must be reported
on Form 5472
* Determine the regulations' impact on DREs and whether a disregarded entity
will be treated as a corporation for Form 5472 filing purposes
* Ascertain applicable penalties for failure to file Form 5472 or maintain
records
* Identify available exemptions and penalty abatement provisions for failure to
file Form 5472 or maintain records
* Recognize the steps that foreign individuals owning DREs operating in the
U.S. must take to fulfill filing requirements
* Field of Study: Taxes.
* Level of Knowledge: Intermediate.
* Advance Preparation: Printing and reviewing Program Outlines and materials.
* Teaching Method: Seminar/Lecture.
* Delivery Method: QAS Self-Study.
* 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 information reporting rules for foreign companies and
individuals engaged in business activities in the U.S.; familiarity with Form
5472 (Information Return of Foreign Corporation Engaged in U.S. Trade or
Business)..
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 credit.
Complaints regarding registered sponsors may be submitted to the National
Registry of CPE Sponsors 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).
Pre-Order CPE On-Demand $236
Download
Downloads include the entire presentation including Q&A. Presentation materials
can be viewed on your screen. PDFs of the presentations are also available on
each program's web page.
Pre-Order Download $197
Can't attend the live event?
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or call 1-800-926-7926
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CPE Credits
Strafford is a NASBA CPE sponsor and this 110-minute webinar is accredited for
2.0 CPE credits.
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Our Guarantee
Strafford webinars 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.
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Tax & Accounting Advisory Board
Griffin H. Bridgers, J.D., LL.M.
Partner
Hutchins & Associates
Christopher Ciminera, CPA, QKA
Principal
Belfint Lyons Shuman
Jeffrey Clayman, JD LLM CPA
Magdalena M. Czerniawski, CPA, MBA
Partner
CBIZ Marks Paneth
Alison N. Dougherty, CPA
Managing Member
Googolplex Tax Services
Jeremiah W. (Jere) Doyle, IV
BNY Mellon Wealth Management
Tara Endy
Director
BDO USA
Pamela A. Fuller
Counsel
Zahn Law Group
Robert W. Jamison, CPA
Brian T. Lovett, CPA, JD
Partner
Withum
Patrick J. McCormick, J.D., LL.M.
Founder/Managing Partner
McCormick Tax
Christopher D. Petermann
Partner
PKF O'Connor Davies
Lawrence K.Y. Pon, CPA/PFS, CFP, EA, USTCP, AEP
Pon & Associates
Stacey L. Roberts, CPA
State and Local Tax Director
TaxOps
Scott Smith
State & Local Tax National Technical Practice Leader
BDO
Michel R. Stein
Principal
Hochman Salkin Toscher Perez
Brian Yacker, JD, CPA
Partner
Baker Tilly
--------------------------------------------------------------------------------
Customer Reviews
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quickly.
Joanna Johnston
Savas Greene & Company
I liked the fact that there was more than one person presenting the material.
It's nice to hear multiple perspectives.
Matt Bristow
Cover & Rossiter
I liked the concentration on specific issues and examples.
Edita Rimalovsky
Komisar Brady & Co.
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