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IRS Form 5471

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Form 5471 Webinar Series: Attribution Rules

Portrait of Phil Hodgen

Phil Hodgen

Attorney, Principal


Form 5471 applies to U.S. persons who own stock of foreign corporations. In this session, we look at the rules for determining stock ownership. Stock may be owned directly, indirectly, or constructively. The attribution rules create most of the complexity, and three different sets of attribution rules apply for Form 5471 purposes.

Presented by Phil Hodgen on May 26, 2023. To join future webinars, sign up to our newsletter and receive updates.

International Tax Lunch Form 5471 -Attribution Rules (Download PDF)