Michael Sardar will present “Form 5471 Substantial Compliance Rules: IRS International Practice Unit Guidance, Pitfalls To Avoid” at Strafford on December 5, 2023. The webinar will be held virtually.

CLE / CPE credit is offered for this event.

Event Description:

This CLE/CPE course will provide tax counsel and advisers with a practical discussion of IRS International Practice Unit (IPU) guidance on what constitutes “substantial compliance” in filing Form 5471, Information Return of U.S. Persons With Respect To Certain Foreign Corporations. The panel will detail the IRS guidance on applying the substantial compliance doctrine and the meaning of “substantially complete” for purposes of the Service’s imposition of penalties related to international information return requirements.

Benefits:
The panel will review these and other highly relevant concepts:

• IRC 6038 information reporting requirements and penalties
• Guidance on Category 4 vs. Category 5 filers
• How the IPU advises examiners to view substantial compliance in light of tax court holdings and prior IRS advice
• Errors “beyond the face” of Form 5471 that will cause an examiner to treat the filing as not substantially complete
• Common errors on Form 5471 that render the filing to be not substantially complete

Speakers:

Michael Sardar, Partner, Kostelanetz LLP

John Samtoy, Tax Partner, Holthouse Carlin & Van Trigt

Click here for more information.