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May 2020 International Tax Lunch: Form 5471 – Categories & Attribution Rules

Form 5471 – Categories & Attribution Rules

U.S. shareholders of foreign corporations must file Form 5471. But how do you know how much stock you own, and indeed if you are even an “owner”? The constructive ownership rules and attribution rules for Form 5471 are complicated, and getting this wrong might mean that you miss a filing requirement. Learn which rules to apply for different categories of Form 5471 filing requirements. Learn how to apply IRC §§318, 6038, and 6046 to find your answers.

Presenter: Phil Hodgen

Materials: Dropbox