Join international tax expert Alison Dougherty on September 12th for an encore presentation of her Strafford webinar, “Mastering Form 5472: New Filing Requirements for Foreign Individuals, LLCs, and Companies” and live questions and answers session. Alison, along with Kristen Burmester of Caplin & Drysdale, will provide line-by-line guidance in successfully completing Form 5472, with a focus on the impact of new IRS regulations requiring 5472 reporting by foreign owners of disregarded entities (DREs).
Form 5472, “Information Return of a 25% Foreign-Owned U.S. Corporation or a Foreign Corporation Engaged in a U.S. Trade or Business,” is one of the most complicated forms applicable to foreign companies. Originally, the reporting obligations applied to corporations only; however, in 2016 the IRS announced changes that extended the reach of Form 5472 requirements to non-U.S. individuals owning DREs active in the U.S. Penalties for failing to file Form 5472 includes fines that could reach up to $10,000 each, with complicated rules for penalty mitigation.
After completing this course, you will be able to:
- Identify key elements of IRC 6038A and 6038C to determine reportable transactions.
- Establish which entities must file Form 5472.
- Recognize reportable transactions with related parties that must be reported on Form 5472.
- Determine the new regulations impact on disregarded entities and whether a disregarded entity will be treated as a corporation for Form 5472 filing purposes.
- Ascertain applicable penalties for failure to file Form 5472 or to maintain records.
- Discern available exemptions and penalty abatement provisions for failure to file Form 5472 or maintain records.