Taxation of U.S. Subsidiaries of Foreign Parents and Preparing Form 5472 (Sold Out)

More than ever, it is critical that you gain a firm understanding of how to plan for tax-efficient structures for U.S. subsidiaries of foreign parents, as the IRS’s onerous reporting requirements require careful preparation. This two-hour CPE webinar presented by former IRS attorney and noted international tax advisor, author and presenter, Robert Misey, LL.M., J.D., M.B.A., explains the tax issues and compliance reporting for U.S. subsidiaries of foreign parents and examines repatriation structures and methods, which rely on the transfer pricing rules.

Mr. Misey, the author of the treatise, U.S. Taxation of International Transactions published by Wolters Kluwer, will demonstrate how to complete a Form 5472 to support inbound planning and avoid tax penalties. What’s more, along with a helpful review of the tax rules, Misey highlights planning opportunities and pitfalls to avoid with U.S. subsidiaries of foreign parent companies.

This course is provides essential learnings for all professionals in public practice or in industries that deal with inbound tax matters - and is especially important today as the IRS has aggressively increased its scrutiny and enforcement activity in the international tax area. Your course materials will include a comprehensive and detailed outline of all topics covered prepared by Mr. Misey to serves as a handy reference for study and review.During the program, time will be provided for you to submit questions directly to Mr. Misey.

Who Should Attend
Business tax and finance executives, directors, managers and staff; CPAs; Enrolled Agents; tax preparers and staff; accountants, attorneys and financial advisors who work with and advise businesses and individuals that have cross-border operations, activities and issues

Topics Covered

• Techniques to repatriate cash from U.S. subsidiaries to foreign parents with minimal withholding taxes
• Analysis of inbound structures, including check-the-box techniques
• The impact of treaties on repatriation
• Tax-advantaged repatriation through aggressive transfer pricing
• Documentation to support a U.S. subsidiary's transfer pricing
• Identifying the relevant parties for completing a Form 5472
• Completing a Form 5472

Learning Objectives

• Explain the principles of efficient repatriation from U.S. subsidiaries to foreign parents
• Describe the role of transfer pricing in repatriation
• Recognize how to complete a Form 5472

Level
Intermediate

Instructional Method
Group: Internet-based

NASBA Field of Study
Taxes (2 hours)

Program Prerequisites
Basic understanding of U.S. federal taxation concepts and U.S. taxation of international transactions

Advance Preparation
None