Doing business in the U.S. via corporations/LLCs?: Do not forget Form 5472

Description

Doing business in the U.S. via corporations/LLCs?: Do not forget Form 5472
IRS Program #: X9QQU-T-01118-24-O
CTEC #: 6257-CE-0280
CE: 1 IRS & 1 CTEC credit
Speaker: Rita Ryan, J.D., LL.M.

Foreign investments in the U.S. commonly involve the use of domestic entities, such as corporations or single member LLCs. In addition to the income tax implications, these types of structures carry filing obligations, such as form 5472. Failure to comply with this reporting obligation results in a penalty of $25,000 USD. This session will describe the scenarios where form 5472 is a relevant consideration, the ins and outs of form 5472 and will discuss some common problematics related to the completion of the form.

Learning Objectives:

Identify scenarios where form 5472 is relevant.
Determine the proper reporting of transactions.
Detect common problematics with form 5472.

Contributors

Rita Ryan, J.D, LLM

Rita leads Wolf’s International Tax Services Practice, where she focuses on tax planning and compliance for international holdings. Rita has extensive experience advising clients on the tax aspects of cross-border business activities, structuring international investments, and the United States compliance obligations relating to these activities and investments for both entities and individuals. Rita also works with other tax professionals as a trusted advisor to identify necessary reporting, advise on filings, or review work papers and prepared forms to ensure accuracy in this evolving international compliance landscape.

Prior to joining Wolf, Rita was in private practice as an Associate Attorney at the law firm of Vacovec, Mayotte & Singer, LLP where she focused in the areas of international and domestic taxation, estate planning, and tax controversy.

Rita is an Adjunct Professor at the Graduate Tax Program at Boston University School of Law where she co-founded and co-teaches “Foreign Information Reporting and Withholding.” She also teaches various other international tax topics for Strafford Publications, Tax Practice Pros, and Wolters Kluwer.

Involvement
- International Fiscal Association (IFA)
- Women of IFA Network (WIN)
- Massachusetts Bar Association
- Allinial Global, Inc.
Education
- Bachelor of Arts in History from Marist College
- Juris Doctor in Law from the Western New England University School of Law
- Master of Laws in Taxation from the Boston University School of Law
- Massachusetts Bar Association Leadership Academy Fellow

Description

Contributors

Rita Ryan, J.D, LLM