Gain the tools and insights needed to manage global business interests effectively and stay ahead of compliance requirements.
Many U.S. taxpayers with ownership in foreign corporations' struggle to understand the complex tax regulations and filing requirements mandated by the IRS, particularly regarding IRS Form 5471. This lack of understanding can lead to significant compliance issues, including substantial penalties and ongoing legal complications. Furthermore, the complexities of Controlled Foreign Corporation (CFC) status, Global Intangible Low-Taxed Income (GILTI) tax, and the attribution rules often create confusion, making it difficult for taxpayers to accurately report their foreign investments. This presentation will equip attendees with the essential knowledge to navigate these complexities confidently. By clearly defining key terms such as CFCs, foreign corporations, and U.S. shareholders, attendees will build a solid foundation of understanding. The webinar will provide a detailed explanation of the criteria for CFC status and the implications of GILTI tax, ensuring that participants can describe these concepts accurately. Attendees will also learn to explain the critical attribution rules and principles of constructive ownership that determine filing obligations. Additionally, the session will help identify the appropriate filing categories and requirements for IRS Form 5471, ensuring compliance with intricate tax regulations.
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Why Lorman?
Over 37 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.
Agenda
Introduction
- Welcome and Overview of the Webinar
- Importance of IRS Form 5471
- Structure and Flow of the Webinar
Key Definitions and Concepts
- Controlled Foreign Corporation (CFC)
- Definition Under Section 957(a)
- Criteria for Classification
- Foreign Corporation
- Definition and Examples
- Distinction From Domestic Entities
- U.S. Shareholder
- Definition and Ownership Thresholds
Basics of Controlled Foreign Corporations (CFCs)
- Understanding CFC Status
- More Than 50% Ownership by U.S. Shareholders
- Voting Power and Value Considerations
- Implications of CFC Status
- Section 951A's Global Intangible Low
- Taxed Income (GILTI) Tax
- Annual Income Reporting Requirements Post2017
Attribution Rules and Constructive Ownership
- Direct, Attribution, and Constructive Ownership Rules
- Treasury Regulations 1.9582
- Family and Related Party Rules
- Exceptions and Special Cases
- Nonresident Aliens and Stock Attribution
- Implications for U.S. Shareholders
Filing Categories for Form 5471
- Overview of Filing Categories
- Category 1 Through Category 5
- Detailed Explanation of Categories
- Category 2: U.S. Officers and Directors
- Category 3: U.S. Persons Acquiring or Disposing of Stock
- Category 4: U.S. Persons With Control of a Foreign Corporation
- Category 5: U.S. Shareholders of a CFC
Filing Requirements and Frequency
- Initial Year Filing Requirements
- Determining the Need to File Form 5471
- Required Forms and Schedules
- Subsequent Year Filings
- Ongoing Filing Requirements Based on Ownership Changes
- Exceptions and Special Circumstances
- Practical Scenarios
- Classifying Foreign Entities
- CheckTheBox Elections and Their Impact
Q and A Session
- Open Floor for Participant Questions
- Clarifications on Complex Scenarios
- Conclusion and Final Thoughts
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Why Lorman?
Over 37 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.
Credits
OnDemand Course
This course was last revised on September 30, 2024.
Call 1-866-352-9540 for further credit information.
This program does NOT qualify, nor meet the National Standard for NASBA accreditation.
MP3 Download
This program does NOT qualify, nor meet the National Standard for NASBA accreditation.
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Why Lorman?
Over 37 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.
Faculty
Alex Oware, CPA, J.D.
O & G Tax and Accounting Services, LLC
- Founder of O&G Tax and Accounting, providing superior financial counsel to individuals and businesses across the globe
- His specialization encompasses diverse areas such as sales/use tax audits, income tax audits, franchise and income tax nexus reviews, and cross-border taxation
- Certified Acceptance Agent working with U.S. resident and non-resident aliens, other foreign taxpayers, and diverse and global clientele
- Extends his expertise to a wide online audience through online consulting at Justanswer.com, where he has answered nearly 12,000 tax-related queries, cementing his role as a trusted and accessible tax advisor
- As an industry thought leader, his insightful perspectives have found their way to the pages of esteemed publications like The Denver Post, WTOP (Washington’s Top News), U.S News & World Report, Yahoo News, Real Simple Online Magazine, The Wall Street Journal, Bloomberg Businessweek, and Ladders News
- Author of several popular articles on complex tax and accounting subjects such as USA – INDIA F-1 & J-1 Tax Treaty, Foreign-Owned U.S. LLCs, and Amazon Foreign Sellers, US Taxation, and 1099-K Reporting
- Studying for a Juris Doctorate from Concord Law School at Purdue University Global
- M.B.A degree in accounting and finance, Colorado Heights University; B.S. degree in accounting and finance, Presbyterian University College of Ghana
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Why Lorman?
Over 37 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.
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