Show navigation

Available in:

OnDemand Course
MP3 Download

Understanding the Complexities of Form 5472 and Its Transfer Pricing Implications

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.

Runtime: 88 minutes

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.

Purchase Options

More Program Information

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.

Agenda

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. §1.6038A1(m)
    • Irm §4.61.3.4.1
  • Documentation Requirements

Completing Form 5472

Statute of Limitations, Penalties and Penalty Abatement

  • IRC §6501(a)
  • IRC §6501(c)
  • IRC §6501(c)(8)
  • IRC §6038A(d), 6038C(c)
Purchase Options

More Program Information

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.

Credits

OnDemand Course

This course was last revised on August 20, 2020.

Call 1-866-352-9540 for further credit information.

  • 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 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.

Purchase Options

More Program Information

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.

Faculty

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
Purchase Options

More Program Information

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.

All of your training, right here at Lorman.

Pay once and get a full year of unlimited training in any format, any time!

  • Live Webinars
  • OnDemand Webinars
  • MP3 Downloads
  • Course Manuals
  • Audio Recordings*
  • Executive Reports
  • White Papers and Articles
  • Sponsored Live Webinars

Additional benefits include:

  • State Specific Credit Tracker
  • Members Only Newsletter
  • All-Access Pass Course Concierge

* For audio recordings you only pay shipping

Questions? Call 877-296-2169 to speak with a real person.

Sign Up Today
With This Course

Access to all training products for one year
$699/year

Unlimited Lorman Training

With the All-Access Pass there is no guessing what you will need for your yearly training budget. $699 will cover all of your training needs for an entire year!

Easy Registrations

Once you purchase your All-Access Pass you will never be any further than one-click away from attending any Lorman training course.

Invest in Yourself

You haven't gotten to where you are professionally by luck alone; it's taken a lot of hard work and training. Invest in yourself with the All-Access Pass.

Product ID: 406409
Published 2020
Purchase Options

Available in Multiple Formats

Purchase this course and learn on your schedule!