Learn what you need to know about the Form 5472 including reporting guidelines and how to complete it properly.
Many U.S. inbound investors are not aware of the complexity, documentation, and financial exposure associated with their requirement to report on Form 5472 inter- and intra-company activities conducted with various related foreign persons and entities. This topic helps identify who has a Form 5472 filing requirement, which transactions should be reported and the filers supporting documentation requirements. The material also explains the expanded statute of limitations potentially applicable to all aspects of the U.S. filer's tax return for failure to file a complete Form 5472 and the sizeable financial penalty and difficult penalty abatement procedures. Failure to properly complete a Form 5472 and maintain proper documentation is one of the most common areas of transfer pricing penalty concerns for U.S. inbound investors.
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Brian D. Dill, JD, LLM
- Principal at Cherry Bekaert
- As the International Tax Practice Leader, he directs the firm’s worldwide resources in developing and delivering practical, customized tax solutions suited for today’s complex global tax landscape
- Provides a full suite of international tax and accounting services for clients, including global tax structuring and tax planning, intellectual property migration strategies, international mergers and acquisitions, transfer pricing, inbound U.S. investment strategies, and import and export strategies
- Since 1995, he has worked to meet the needs of growth-oriented clients in the industrial and manufacturing sectors, as well as those in the technology, software, and health & life sciences industries
- Fortune 1000 corporations, middle-market private companies, venture-backed businesses and others have also benefited from his guidance
- Prior to joining Cherry Bekaert, he served as an international tax principal for a national firm; he has also held senior international tax positions at two Big Four firms
- LL.M. degree in taxation, Denver University; J.D. degree, University of Tulsa College of Law; M.S. degree in accountancy, Bentley College; B.B.A. degree in finance and eco-nomics, Baylor University
William Y. Hooker, CPA, JD
- Director, International Tax Services at Cherry Bekaert
- Licensed CPA and attorney with experience in audit, business administration and tax, and specialty experience focusing solely in international tax consulting and compliance
- Has accumulated a broad array of global business experience with positions at Arthur Andersen, a publicly traded global media company and two Big Four firms
- Based in Atlanta, he has advised a wide variety of companies on numerous inbound and outbound international tax consulting, compliance and global structuring issues
Kirk A. Hesser, MS
- Managing director at Cherry Bekaert and serves as the National Leader of the Firm’s Global Transfer Pricing practice
- With over 25 years of professional experience, he specializes in serving the transfer pricing and international tax needs of the firm’s multinational clients
- Specific expertise includes transfer planning and savings strategies, global transfer pricing compliance documentation, transfer pricing controversy defense, and partnering with industry and outside legal advisors defending and structuring complex global business transactions
- Industry background includes implementation of transfer pricing strategies for clients’ products, services and intangibles in the manufacturing, distribution, real estate, technology, transportation and logistics sectors
- Also serves as a resource for THInc, the firm’s specialty practice that caters to the innovative needs of companies in the technology, health and life sciences, and industrial sectors
- Prior to joining Cherry Bekaert, he held senior tax director and principal positions within the international tax practices of Big Four and national accounting and consulting firms
- A well-respected and sought-after speaker on transfer pricing issues
- M.S. and B.S. degrees in economics, Oklahoma State University
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