ITL 2023: Form 5471: Restructuring, Reorganization, and Liquidation of a CFC

Description

CFCs are generally painful for U.S. tax purposes. In this session, we explore the rules for reorganizing or eliminating CFCs in order to reduce tax costs and compliance burdens. Topics include tax-free reorganizations and creative use of the check-the-box rules to make things less bad.

Highlights

• Form 5471
• Controlled foreign corporation
• Entity structuring
• Entity liquidation

Objectives

• Identify options for restructuring and reorganizing to reduce filing burdens
• Determine whether an entity can make use of a reorganization

Designed For

CPAs, attorneys, tax preparers and advisors who what to stay current on the latest developments on international tax issues.