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Live Webinar

90-minute live streaming program
  • August 20
  • 1:00 - 2:30 pm EST

Understanding the Complexities of Form 5472 and Its Transfer Pricing Implications

August 20

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.

Learning Objectives

  • You will be able to identify the essential requirements of Form 5472 in order for you to properly determine applicable reportable transactions, reportable corporations and related parties.
  • You will be able to describe how Form 5472 is one of the most complicated IRS forms concerning foreign persons, the application of the extended stature of limitations and the $25,000 penalty.
  • You will be able to discuss the interplay between transfer pricing and Form 5472.
  • You will be able to identify commonly missed reportable transactions involving inter-branch transactions between U.S. disregarded entities and intra-company transactions between a U.S. disregarded entity and a foreign person.

Learn the fundamentals and complexities of Form 5472.

Get a strong understanding of the repatriation method for dividends, debt financing(interest), service and management fees and royalties. Learn who is a related party and what section a related party is pursuant to.

Determine the Nature and Amount of Reportable Transactions for Form 5472

In this course we will also cover and teach you how to determine the nature and amount of reportable transactions. We cover inter-company transactions, what a transfer price is and what the IRC Section 482 requires for inter-company transactions to be priced at. You will learn what the transfer pricing penalty is and how the IRS determines a transfer pricing penalty. We cover the transfer pricing documentation requirements and so much more.

Your home for learning Form 5472 and many more tax and accounting courses

Lorman Education Services has been providing tax and accounting training for over 25 years. Our topics are built to teach you the hard skills of your profession and to give you the best, most up to date tax and accounting knowledge. Our tax courses hep you stay compliant and keep the IRS from knocking on your door.

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Why Lorman?

Over 33 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.


Form 5472 and Its Statutory Authority
  • IRC §6038A
  • IRC §6038C
Applicable Form 5472 Entities, Individuals, and Definitions
  • Direct and Ultimate Indirect 25% Shareholders
  • Rev. Proc. 91-55
  • Key Terms
    • Reporting Corporation
    • Reportable Transaction
    • Related Party
Latest Development: Reporting for Domestic Disregarded Entities Separate From Foreign Persons
  • Treasury Decision 9796
  • Treasury Regulation Section 301.7701-2
  • Treasury Regulation Section 1.6038A-0
  • Treasury Regulation Section 1.6038A-2
  • Treas. Reg. §1.6038A-2(b)(9) e.g., 1 – Reporting for U.S. Disregarded Entity
  • Treas. Reg. §1.6038A-2(b)(9) e.g., 2 – Reporting for Transactions Between U.S. Disregarded Entities
Transfer Pricing and Form 5472
  • Transactions to Report
    • Treas. Reg. §1.6038A-1(m)
    • Irm §
  • Documentation Requirements
Completing Form 5472
Stature of Limitations, Penalties and Penalty Abatement
  • IRC §6501(a)
  • IRC §6501(c)
  • IRC §6501(c)(8)
  • IRC §6038A(d), 6038C(c)
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Why Lorman?

Over 33 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.


Live Webinar Registration

  • Enrolled Agents 1.0
  • This program qualifies for 1.0 hours of Continuing Education Credit for enrolled agents under Treasury Department Circular #230 Section 10.6(g).
  • This is an IAPP qualifying continuing education activity.
  • CPE 1.8 including Taxes 1.8
  • Lorman Education Services 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 web site: For more information regarding administrative policies such as complaint and refund, please contact our offices at 866-352-9539. CPE Credit: Maximum Credit Hours: 1.8 each session (based on a 50 minute credit hour). You must attend at least 50 minutes to obtain credit. Field of Study: Taxes for 1.8 hours. Prerequisite: basic knowledge of taxation. Level of Knowledge: Intermediate. Teaching Method: Seminar/Lecture. Advance Preparation: None. Delivery Method: Group Internet Based. Please refer to the information in this brochure for outline, course content and objectives. Upon completion of this course, you will receive a certificate of attendance. Final approval of a course for CPE credit belongs with each state's regulatory board. Please note: In order to receive CPE credit for this course you MUST use the streaming audio option, as well as enable and complete the required progress checks.
  • Lorman Business Center, LLC. is a registered provider for CPA CPE through the State Education Department of New York, Sponsor number: 000640. The following course will carry the subject area of Taxation for 1.5 hours.

Who should attend?

This live webinar is designed for accountants, tax managers, CPAs, presidents, vice presidents, business owners and managers, CFOs, controllers, enrolled agents, CEOs, and finance directors.

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Why Lorman?

Over 33 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.


Brian D. Dill, JD, LLM

Brian D. Dill, JD, LLM

Cherry Bekaert

  • 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
Kirk A. Hesser, MS

Kirk A. Hesser, MS

Cherry Bekaert

  • 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
William Y. Hooker, CPA, JD

William Y. Hooker, CPA, JD

Cherry Bekaert

  • 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
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Over 33 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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Product ID: 406409
Published 2020
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