Taxation of Foreign-Owned U.S. Corporations and Completing Form 5472
Author: Robert J. Misey
| CPE Credit: |
2 hours for CPAs
2 hours Federal Tax Related for EAs and OTRPs
2 hours Federal Tax Law for CTEC |
Per the IRS Education Provider Standards this course must be COMPLETED by 12/31/2027 to receive credits. NOTE: Go to My Professional Profile in your CCH CPELink account settings to ensure your name, and PTIN number; matches your PTIN card
With the expansion of global business, the number of foreign-owned U.S. companies has increased exponentially. These companies have significant intercompany transactions with their foreign parents that they have to report on Form 5472, the Information Return of a 25% Foreign-Owned U.S. Corporation.
Publication Date: August 2024
Topics Covered
- The Form 5472 filing requirements
- Understanding the various parts of Form 5472
- Identifying the various intercompany transactions
- The methods to determine the arm's length price of intercompany transactions
- How to avoid the transfer pricing penalties
- Failing to file Form 5472 and the related penalties
- Completing a sample Form 5742
Learning Objectives
- Identify the tax law behind the informational requirements on Form 5472
- Identify U.S. international tax reporting and compliance with respect to foreign-owned U.S. corporations
- Identify the IRC whose principles require that intercompany transactions be priced at arm's length
- Identify the price charged for intercompany transactions
- Identify one of the limitation on benefits articles that prevents treaty shopping
Level
Basic
Instructional Method
Self-Study
NASBA Field of Study
Taxes (2 hours)
Program Prerequisites
None
Advance Preparation
None
