IRS Form 1099, 1099-NEC, and Form 1099-MISC: Advanced Issues and Updates

Understanding the Complexities of Form 5472 and Its Transfer Pricing Implications

$219.00

SKU: 411100

Description

Learn what you need to know about Form 5472 including reporting guidelines and how to complete it properly.
Many companies who are required to prepare annual transfer pricing documentation and support for their intercompany transactions often do not understand that they need to do so, or what is needed in order to satisfy the US transfer pricing regulations. Additionally, these same companies likely do not understand the serious impacts transfer pricing has on their annual corporate income tax return, leaving them exposed to potentially large proposed tax adjustments and double taxation in the event of an IRS examination. This presentation will help attendees understand first what the transfer pricing rules and requirements are, and then how to intelligently comply while also keeping in mind any possible tax planning opportunities transfer pricing tends to present.

Date: 2024-05-22 Start Time: 1:00 PM ET End Time: 2:40 PM ET

Learning Objectives

* You will be able to define the arms length standard with respect to the US transfer pricing regulations, as well as the highlevel US transfer pricing concepts associated.

* You will be able to describe the importance of transfer pricing with respect to mitigating a companys tax exposure, while balancing possible tax planning opportunities.

* You will be able to discuss the various transfer pricing requirements needed to be in full compliance with the US transfer pricing requirements.

* You will be able to explain the impacts of incorrect transfer pricing on a companys tax return and the risk exposure it creates.

What Is Transfer Pricing?
• Definitions
• History
• Current Landscape

Why Is It Important?
• Eliminate Double Taxation
• Documentation and Agreement Requirements
• Efficient Tax Planning

How Is It Used?
• Transaction Buckets
• Cash Flow Planning
• Case Study Examples

Regulatory Requirements
• Documentation and Timing
• Foreign Divergences
• Customs Implications

Effects on Us Tax Return and Foreign Implications
• Forms 5471/5472
• Form 8858/8865
• FTC

AIPB ,Enrolled Agents ,CPE ,Additional credit may be available upon request. Contact Lorman at 866-352-9540 for further information.

Carl Budenski-Aprio, Yan Jiang – Aprio

IRS Form 1099, 1099-NEC, and Form 1099-MISC: Advanced Issues and Updates

Understanding the Complexities of Form 5472 and Its Transfer Pricing Implications

$219.00

SKU: 406409

Description

Learn what you need to know about the Form 5472 including reporting guidelines and how to complete it properly.
Many U.S. inbound investors are not aware of the complexity, documentation, and financial exposure associated with their requirement to report on Form 5472 inter and intracompany activities conducted with various related foreign persons and entities. This topic helps identify who has a Form 5472 filing requirement, which transactions should be reported and the filers supporting documentation requirements. The material also explains the expanded statute of limitations potentially applicable to all aspects of the U.S. filers tax return for failure to file a complete Form 5472 and the sizeable financial penalty and difficult penalty abatement procedures. Failure to properly complete a Form 5472 and maintain proper documentation is one of the most common areas of transfer pricing penalty concerns for U.S. inbound investors.

Date: 2020-08-20 Start Time: 1:00 PM ET End Time: 2:30 PM ET

Learning Objectives

* You will be able to identify the essential requirements of Form 5472 in order for you to properly determine applicable reportable transactions, reportable corporations and related parties.

* You will be able to describe how Form 5472 is one of the most complicated IRS forms concerning foreign persons, the application of the extended stature of limitations and the 25,000 penalty.

* You will be able to discuss the interplay between transfer pricing and Form 5472.

* You will be able to identify commonly missed reportable transactions involving interbranch transactions between U.S. disregarded entities and intracompany transactions between a U.S. disregarded entity and a foreign person.

Form 5472 and Its Statutory Authority
• IRC §6038A
• IRC §6038C

Applicable Form 5472 Entities, Individuals, and Definitions
• Direct and Ultimate Indirect 25% Shareholders
• Rev. Proc. 91-55
• Key Terms
• Reporting Corporation
• Reportable Transaction
• Related Party

Latest Development: Reporting for Domestic Disregarded Entities Separate From Foreign Persons
• Treasury Decision 9796
• Treasury Regulation Section 301.7701-2
• Treasury Regulation Section 1.6038A-0
• Treasury Regulation Section 1.6038A-2
• Treas. Reg. §1.6038A-2(b)(9) e.g., 1 • Reporting for U.S. Disregarded Entity
• Treas. Reg. §1.6038A-2(b)(9) e.g., 2 • Reporting for Transactions Between U.S. Disregarded Entities

Transfer Pricing and Form 5472
• Transactions to Report
• Treas. Reg. §1.6038A-1(m)
• Irm §4.61.3.4.1
• Documentation Requirements

Completing Form 5472

Stature of Limitations, Penalties and Penalty Abatement
• IRC §6501(a)
• IRC §6501(c)
• IRC §6501(c)(8)
• IRC §6038A(d), 6038C(c)

CPE ,Enrolled Agents ,IAPP ,Additional credit may be available upon request. Contact Lorman at 866-352-9540 for further information.

Brian D. Dill, JD, LLM-Cherry Bekaert, Kirk A. Hesser, MS – Cherry Bekaert, William Y. Hooker, CPA, JD – Cherry Bekaert