Be confident in your IRS Form 5471 filing skills and avoid costly audits and penalties.
Form 5471, Information Return of U.S. Persons with Respect to Certain Foreign Corporations, is an annual tax reporting obligation of U.S. shareholders owning foreign corporations to disclose information like financial position, related party transactions, earnings and profits, changes in the ownership structure of foreign corporation, Subpart F income and G.I.L.T.I. income of the U.S. shareholder. A failure to timely file Form 5471 attracts a heavy penalty which makes it imperative to understand the triggering event for such reporting obligation.
This material will help you develop a basic understanding of the process of identifying U.S. persons subject to the reporting obligation, the attribution rules to determine the U.S. filer status, the extent of reporting and differences in how attribution rules apply for reporting purposes versus other purposes of the Code such as the Subpart F provisions, including GILTI. These topics will be explained with the help of examples and relevant code sections and regulations that will assist you in the application of the regulations to specific facts to facilitate better understanding.
Agenda
Faculty
Andreas Apostolides
Ruchelman P.L.L.C.
- Associate with Ruchelman P.L.L.C.
- Offers thoughtful and thorough advice to his clients and helps them find significant efficiencies in structuring cross-border transactions and reorganizations
- Started his tax career at the Washington, D.C. National office of Ernst & Young, LLP where he helped clients structure their transactions on a tax efficient basis and obtain favorable rulings from the I.R.S; thereafter, he obtained practical experience in the in-house setting, serving as tax counsel to a large global publicly-traded company in the D.C. Metro area and later to a Brooklyn-based media company
- LL.M. degree, Georgetown University; J.D. degree, University of Pennsylvania; B.A. degree, Harvard College
- Can be contacted at 212-755-3333 or [email protected]
Neha Rastogi
Ruchelman P.L.L.C.
- Associate with Ruchelman P.L.L.C.
- Known for her thorough and professional approach to international tax matters; at Ruchelman, she regularly advises domestic and foreign clients on tax-efficient structuring
- Cross-border practice is informed by her diverse experience in the tax environment
- Before joining the firm, she qualified as an advocate and a member of the Institute of Chartered Accountants of India and worked at a leading tax law firm based in New Delhi; there she focused on planning and controversy matters, advising on the corporate income tax implications of activities in India as well as personal income tax and related compliance obligations
- Recent client matters have involved the application of Subpart F, F.I.R.P.T.A., the entity classification and foreign tax credit rules, and international tax treaties, among other issues
- LL.M. degree, New York Law School; LL.B. degree, University of Delhi
- Can be contacted 212-755-3333 or [email protected]
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