Taxation of U.S. Owners of Foreign Corporations and Completing Form 5471 :-

With more companies conducting business globally, the number of foreign subsidiaries has exploded. That leaves many U.S. owners needing to know the tax rules and file Form 5471, Information Return of U.S. Persons With Respect To Certain Foreign Corporations. The IRS is aggressively pursuing penalties for non-filing, so Form 5471 compliance is critical to understand.

Topics Covered

• Weeding through the confusing Form 5471 filing categories
• Determining Subpart F income that must be reported on Schedule I and Global Intangible Low-Taxed Income that must be reported on Schedule I-1
• Determining which foreign taxes are creditable
• Translating items denominated in foreign currencies
• Reporting intercompany transactions on Schedule M
• Failing to file Form 5471 and the related penalties
• Completing a sample Form 5741 for the revised version of the form

Learning Objectives:

• Understand the tax law behind the informational requirements on Form 5471
• Develop a practical understanding of U.S. international tax reporting and compliance with respect to foreign corporations

Who Should Attend?

• CPA
  
• Enrolled Agents (EAs)
• Tax Professionals
• Attorneys
• Other Tax Preparers
• Finance professionals
  
• Financial planners

Credits and Other information:

• Recommended CPE credit – 2.0
  
• Recommended field of study – Taxes
• Session Prerequisites and preparation: None
• Session learning level: Basic
• Location: Virtual/Online
• Delivery method: Group Internet Based
• Attendance Requirement:  Yes
• Session Duration: 2 Hours
• Case Studies and Live Q&A session with speaker
  
• PowerPoint presentation for reference

Speaker Profile:

Robert J. Misey

Rob Misey is a shareholder with the law firm of Reinhart Boerner Van Deuren s.c. and Chair of the firm's International Department. He concentrates his practice in the areas of international taxation, transfer pricing and tax controversies, and works with a wide range of clients from a variety of industries including manufacturing, service, energy, retail and entertainment.

For U.S. based multinationals, Rob helps clients maximize foreign tax credits and take advantage of export benefits to reduce the client's overall effective tax rate. For foreign owned clients, he coordinates with the client's global tax minimization strategy, using repatriation techniques to minimize U.S. withholding taxes. Rob's significant transfer pricing experience allows him to assist multinational businesses with preparing documentation and negotiating Advance Pricing Agreements (APAs). He assists both U.S. and foreign investors in minimizing withholding taxes by taking advantage of applicable tax treaties and offshore corporations and trusts.

Rob's previous experience includes nine years as an attorney for the IRS. While he was with the IRS, he served as an international tax attorney in its Washington, D.C. national office, where he was a member of the APA team, and a trial attorney and international tax specialist in San Jose, California and the Southeast Region. He also managed the International Tax Services group for a region of a Big Four accounting firm.

Rob regularly shares his expertise and experience on international taxation with business and professional audiences at continuing education programs in numerous states and foreign countries. He has published numerous articles and is a co-author to treatises, U.S. Taxation of International Transactions and Federal Taxation Practice and Procedure, both published by CCH. Rob also teaches international taxation at the Master of Tax program in the University of Wisconsin system.

Rob received his Juris Doctor and Master of Business Administration degrees from Vanderbilt University and his Master of Laws in Taxation, with high distinction, from Georgetown University, where he was the graduate student editor of The Tax Lawyer. A native of Milwaukee, Mr. Misey is licensed to practice in Wisconsin, California and the District of Columbia. His professional affiliations include membership in the Tax Section of the District of Columbia Bar Association. He is also a former Chair of the International Practice Section of the Wisconsin State Bar.