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STEP/LA Luncheon Presentation featuring STEVEN TOSCHER – Festival of Forms Featuring Form 5471 Substantial Compliance Rules


Friday, February 16, 2018

12:00 p.m. – 1:30 p.m.

Northern Trust
2049 Century Park East, Suite 3600
Los Angeles, CA 90067

Steven Toscher of Hochman Salkin Rettig Toscher & Perez and John Apuzzo of PricewaterhouseCoopers LLP, will discuss an interesting topic about the encore presentation the Strafford webinar, “Form 5471 Substantial Compliance Rules: New IRS International Practice Unit Guidance.

Form 5471, Information Return of U.S. Persons with Respect to Certain Foreign Corporations, is one of the most complex reporting obligations in the U.S. offshore information tax reporting regime. A taxpayer who fails to file a “substantially complete” Form 5471, absent reasonable cause, is subject to severe monetary and other penalties, beginning at $10,000 per year per missed form.

Our panel will provide tax counsel and advisers with a practical discussion of recent IRS International Practice Unit (PU) 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 application of the substantial compliance doctrine, and the meaning of “substantially complete” for purposes of the Services imposition of penalties related to International information return requirements.

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