Learn what you need to know about Form 5472 including reporting guidelines and how to complete it properly.
Many companies who are required to prepare annual transfer pricing documentation and support for their intercompany transactions often do not understand that they need to do so, or what is needed in order to satisfy the US transfer pricing regulations. Additionally, these same companies likely do not understand the serious impacts transfer pricing has on their annual corporate income tax return, leaving them exposed to potentially large proposed tax adjustments and double taxation in the event of an IRS examination. This presentation will help attendees understand first what the transfer pricing rules and requirements are, and then how to intelligently comply while also keeping in mind any possible tax planning opportunities transfer pricing tends to present.
Learn the fundamentals and complexities of Form 5472.
Get a strong understanding of the repatriation method for dividends, debt financing(interest), service and management fees and royalties. Learn who is a related party and what section a related party is pursuant to.
Determine the Nature and Amount of Reportable Transactions for Form 5472
In this course we will also cover and teach you how to determine the nature and amount of reportable transactions. We cover inter-company transactions, what a transfer price is and what the IRC Section 482 requires for inter-company transactions to be priced at. You will learn what the transfer pricing penalty is and how the IRS determines a transfer pricing penalty. We cover the transfer pricing documentation requirements and so much more.
Your home for learning Form 5472 and many more tax and accounting courses
Lorman Education Services has been providing tax and accounting training for over 25 years. Our topics are built to teach you the hard skills of your profession and to give you the best, most up to date tax and accounting knowledge. Our tax courses hep you stay compliant and keep the IRS from knocking on your door.
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Agenda
What Is Transfer Pricing?
- Definitions
- History
- Current Landscape
Why Is It Important?
- Eliminate Double Taxation
- Documentation and Agreement Requirements
- Efficient Tax Planning
How Is It Used?
- Transaction Buckets
- Cash Flow Planning
- Case Study Examples
Regulatory Requirements
- Documentation and Timing
- Foreign Divergences
- Customs Implications
Effects on Us Tax Return and Foreign Implications
- Forms 5471/5472
- Form 8858/8865
- FTC
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Why Lorman?
Over 37 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.
Credits
OnDemand Course
This course was last revised on May 22, 2024.
Call 1-866-352-9540 for further credit information.
- AIPB 2.0
- This program is acceptable for 2.0 CPEC(s) towards the CB designation through the American Institute of Professional Bookkeepers (AIPB).
This program does NOT qualify, nor meet the National Standard for NASBA accreditation.
MP3 Download
This program does NOT qualify, nor meet the National Standard for NASBA accreditation.
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Why Lorman?
Over 37 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.
Faculty
Carl Budenski
Aprio
- Director and Co-leader of Aprio’s National Transfer Pricing Practice, also leading Aprio’s burgeoning Benelux practice
- Aprio’s transfer pricing expertise spans various global industries such as manufacturing, distribution, technology, and digital assets, with dedicated country groups for UK, Germany, Korea, China, Japan, and Australia/New Zealand
- Conducted numerous seminars and trainings on transfer pricing, and how it impacts businesses around the world, including a recent engagement for the Belgian Chamber of Commerce
- Author of numerous articles regarding transfer pricing
- M.S. degree in Finance and Economics, West Texas A&M University; B.B.A. degree in both Finance and Economics, magna cum laude, Drake University
- Can be contacted at (470) 694 6218; [email protected]; or https://www.linkedin.com/in/carl-budenski/
Yan Jiang
Aprio
- International Tax Consulting and Tax Director at Aprio
- Experience includes addressing the tax complexities associated with a variety of multinational business structures and cross-border transactions
- Extensive experience in international mergers and acquisitions, such as tax due diligence and restructuring
- Has assisted clients with various transactional projects dealing with international tax risk assessment, U.S. anti-deferral tax planning (CFC, Subpart F income, GILTI, foreign tax credit), and offshore cash expatriation
- Conducts both public and private seminars in the international tax area, recently delivering a series of international tax training sessions to a global financial institution, educating its bankers with the knowledge to navigate their clients’ cross-border tax issues
- M.B.A. degree and M.S. degree in Accounting, California State University, Los Angeles
- Can be contactad at (240) 630-1032; [email protected]; or https://www.linkedin.com/in/yan-jiang-6a570831/
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