• videocam On-Demand Webinar
  • signal_cellular_alt Intermediate
  • card_travel Tax Preparation - Foreign
  • schedule 110 minutes

Form 5471 Attribution Rules: Categories of Filers and Rev Proc 2019-40 Safe Harbors

$197.00

This course is $0 with these passes:

CPE
ALL
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About the Course

Introduction

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.

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.

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

    Thursday, June 13, 2024

  • schedule

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

  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

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

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.

BARBRI, 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

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 Barbri-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 .