Learn How to Meet Information Reporting Obligations for Foreign Entities
The compliance burdens on U.S. businesses are immense and seem to grow in number and complexity each year. This is especially true for American taxpayers with overseas operations and activities. U.S. taxpayers that are controlling shareholders of controlled foreign corporations (CFCs) are required to file Form 5471, Information Return of U.S. Persons with Respect to Certain Foreign Corporations each year. Reporting the results of foreign entities with complete and accurate 5471s and related forms and schedules, however, is easier said than done—the complexities and challenges of just gathering the necessary data for foreign entities can be formidable, plus there are currency and accounting method differences to contend with, and a host of other issues that present significant burdens on taxpayers to provide the government with the compliance information it now requires. What’s worse is that doing it wrong or being late can result in very hefty penalties ($10,000 for each annual accounting period of each CFC’s failure to furnish the required information within the required time period).
This two-hour audio seminar on Thursday, September 4th will help you understand the fundamentals of U.S. international tax reporting and compliance and the preparation and filing Forms 5471. Presented by noted international tax advisor, author and presenter, William "Bill" Elliot, CPA, ABV, LL.M., this program will provide a helpful review of the increasingly heightened disclosure obligations for U.S. taxpayers with ownership interests in foreign entities and help you better manage the overall compliance process. In addition to concise and practical discussions of the key reporting rules and requirements, Mr. Elliott will walk through case scenarios and illustrate how information on related foreign entities flows through onto the applicable forms. Time will be provided for you to ask your most pressing questions directly to Mr. Elliott via phone or e-mail.
Program Topics
Review of fundamental U.S. international tax reporting rules and obligations for foreign entities
Purpose of Form 5471
Structure and preparation of the Form 5471
Who must file and filing requirements
Securing the necessary tax data from related foreign entities
Treatment of intracompany activities and transactions
Special rules and requirements for foreign disregarded entities
Computing Code Sec. 987 foreign currency translation gains and losses
Potential audit issues and triggers to avoid
New IRS initiative to examine foreign controlled corporation returns using Form 5471s in the selection process
Filing relief for Dormant Foreign Corps
Relief for late or non-filings
Learning Objectives
Develop a solid understanding of U.S. international tax reporting and compliance for foreign entities
Understand the steps required to properly file Form 5471
Gain awareness of potential problem areas and pitfalls to avoid
Who Should Attend
All corporate tax professionals, CPAs and tax attorneys involved with the preparation or review of international tax returns will benefit from this insightful seminar.
Register today for this convenient program on Thursday, September 4 at 1pm Eastern, Noon Central, 10am Pacific.
William (Bill) Perry Elliott, CPA, J.D., LL.M., ABV is the head of the Mahoney Cohen & Company, CPAs’ International Tax and Consulting practice and a shareholder of the firm. Mr. Elliott’s practice area extends to all aspects of international taxation, including domestic and offshore captive insurance companies, inbound and outbound entity transactions, estate and income tax planning for foreign persons in the U.S., transfer pricing, valuation of intangible and intellectual property for domestic and outbound transactions, including the design and formation of qualified cost sharing arrangements, specializing in the transfer of the non-U.S. exploitation rights in IP to foreign entities, trusts and estates, asset protection planning with domestic and international applications, valuations for tax purposes, captive insurance arrangements, and corporate and passthrough entity taxation and consulting.
Mr. Elliott writes and edits extensively, including contributions to CCH’s TAXES: The Tax Magazine and 1120S Express Answers, the Journal of International Taxation, Tax Notes International, and other leading tax journals and publications. He also is developer of and contributor to self-study CPE programs in the areas of international tax, valuation and S corporations. Mr. Elliott speaks both domestically and worldwide for state CPA societies and other leading U.S. tax and international tax programs directed to practitioners, as well as programs for individuals and companies needing technical and practical guidance in his areas of expertise.
Mr. Elliott is an honors graduate of Millsaps College in Jackson, Mississippi, from which he received a B.A. in accounting degree. He also holds a Juris Doctor (J.D.) degree and Master of Law degree (LL.M.) in international taxation from St. Thomas University School of Law in Miami, Florida, from which he graduated summa cum laude. Mr. Elliott is a member of the AICPA and the Tennessee, Georgia, and Mississippi CPA Societies; and is licensed to practice as a CPA in New York, Alabama and Mississippi. Additionally, he is a credentialed business valuation and appraisal professional, holding the ABV (Accredited in Business Valuation by the American Institute of CPAs) and CVA (Certified Valuation Analyst from NACVA) designations. Mr. Elliott is also a member of the International Fiscal Association (IFA) based in the Netherlands.
Prior to joining Mahoney Cohen, Mr. Elliott served as managing member of Decosimo Global, the international tax and consulting division of Decosimo, a regional CPA, finance and advisory firm. In addition to his international tax role, Mr. Elliott was a tax principal at Decosimo, and a valuation practitioner within Decosimo Corporate Finance, a division of Decosimo CPAs.
How the Audio Seminar Works
CCH’s live audio seminars require nothing more than a telephone connection. For the single per-site fee, you can have an unlimited number of listeners at your site participate, get up to speed and in-the-know on important topics, and get special bonus publications included with the seminar. Handout materials are provided in PDF format that you can download and copy for all those who will participate in the seminar at your location.
Practice Development Tip! Invite colleagues, business referral sources, clients and prospects to your office to listen in and participate on this seminar with you. They’ll appreciate your invitation to hear directly about this important topic.
If you are unable to attend this upcoming event and would like to order a recording—or if you would like to order recordings of past CCH Audio Seminars, please visit the CCH Audio Seminar Archive Library today.
Pricing:
Site License: $249 – Registration includes one telephone connection at one location, one master set of handouts (with permission to make additional copies for the participants at your location), an unlimited number of people in one listening room can participate, and one seminar bonus publication per registered site. ($25 CPE fee additional for each person wishing to receive a CPE certificate for their participation.)
CD Recording: $249 – The CD includes an audio recording of the event and handout materials in PDF format. Includes copy of seminar bonus publication with purchase. Available one week after the live audio seminar event. (Note: CPE credit is not available for the CD version of the presentation.)
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