Cross-Border Ownership Structures: Lessons Learned Under Tough IRS Scrutiny

Webinar: ID# 1026132
Recorded CD
About This Course:
This webinar will help improve your client’s or company’s compliance regarding timely and accurately filing IRS forms disclosing corporate foreign ownership structures.

You will learn from the real world experiences of tax advisers familiar with data demands from Forms 1120-F, 926, 5471 and 5472, and who are veterans in dealing with IRS oversight of foreign ownership structures. This panel of seasoned accounting advisers will help you stay fully compliant with the IRS’s evolving expectations for reporting on foreign ownership.

Course Outline
  • IRS enforcement and audit environment to date
    • Background on tougher Form 5471 penalties, and frequency with which they’ve been imposed
    • Penalty structure for forms 5472, 1120-F and 926; recent audit activity
  • Forms 5471 and 5472
    • Difficult compliance issues
  • Form 1120-F and its schedules
    • Difficult compliance issues
  • Form 926
    • Difficult compliance issues

The panel will prepare you for these and other crucial aspects:
  • Understanding—and taking—the preventive steps to avoid costly penalties and interest, branch profits tax assessments, audits, and other negative events
  • Planning for an IRS audit of foreign ownership connections based on enforcement activities to date
  • Mastering the details regarding value, costs and gains on transferred assets, direct and indirect expense allocations, and other disclosures required on forms 5471, 5472, 1120-F and 926
Learning Objectives

Upon completion of this webinar, you will be able to:
  • Identify the data demands on forms 5471, 5472, 1120-F and 926
  • Recognize penalty structure for forms 5471, 5472, 1120-F and 926
  • Discern details regarding value, costs and gains on transferred assets, direct and indirect expense allocations, and other required disclosures
How To Access Course And Materials

Handout materials and the phone number for live presentations are made available to you one day prior to the event via email from the presenter. Copies of the presentations are included with recorded versions.

If you order a recorded version of the webinar, CDs will be mailed out approximately 10 days after the live event. Shipping is included in the price of recorded versions.

Continuing Education Credits Available

This program has been approved for 2.0 CPE hours through Strafford Publications. To obtain CPE credit, attendees must participate in the live event (recorded versions do not qualify for credit), return an Official Record of Attendance to Strafford affirming their participation (including the CPE code announced during the program), and pay a processing fee of $35 per person.

Strafford will mail a certificate of credit within approximately two weeks of receiving your completed Official Record of Attendance, provided all required conditions have been satisfied.

Strafford 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.
Cross-Border Ownership Structures: Lessons Learned Under Tough IRS Scrutiny
Available on CD format
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