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Taxation of U.S. Subsidiaries of Foreign Parents and Preparing Form 5472

TAXATION OF U.S. SUBSIDIARIES OF FOREIGN PARENTS AND PREPARING FORM 5472

Cost $15.00
Presentation Length 1.0 hour

Recorded DateSeptember 30, 2020
CPE:Not available
(archived webinars do not offer CPE credits)
Subject AreaTaxes
Course LevelBasic
Course Description

More than ever, it is important that you plan for tax-efficient structures for U.S. subsidiaries of foreign parents - and properly comply with the onerous IRS reporting requirements. This program will evaluate the planning issues and compliance reporting for U.S. subsidiaries of foreign parents, as well as repatriation structures and methods, which rely on the transfer pricing rules. This subject is important for all tax professionals in public practice and in the industry who deal with inbound planning and compliance issues.

Learning Objectives:


  • Identify tax-efficient inbound structures to repatriate cash

  • Recognize the impact of treaties on repatriation

  • Identify tax-advantaged repatriation through aggressive transfer pricing

  • Identify the relevant parties for completing a Form 5472

  • Complete a sample Form 5472

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PLEASE NOTE: ARCHIVED WEBINARS DO NOT QUALIFY FOR CPE
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Robert Misey, J.D., LL.M.

Reinhart Boerner Van Deuren s.c.
Chair of the International Department
[email protected]
(312) 207-5456

Reinhartboernervan

Robert Misey leads the International Department for the law firm of Reinhart Boerner Van Deuren and is a former trial attorney for the IRS Chief Counsel (International) in Washington, DC. Robert is Chair of the International Tax Committee for the ABA and a member of the bar in California, Wisconsin, and the District of Columbia. He is also the author of the book, A Practical Guide to U.S. Taxation of International Transactions and Federal Taxation: Practice and Procedure.

About Our Presenter

Reinhartboernervan
At Reinhart Boerner Van Deuren, we know that every trusted relationship begins with understanding. That is why each of our committed attorneys takes the time to listen critically, learn the unique attributes of each client’s business, and work together to build a foundation for success that goes beyond providing legal services. While doing so, we draw upon an exceptionally broad base of experienced attorneys and deep knowledge of the industries and sectors we serve. This blend of active understanding grounded by informed perspective equips our attorneys to deliver uniquely creative, yet efficient, legal counsel.