A Deep Dive Into the IRS Form 5741 Attribution Rules, Form 5471 Category of                                               Filers, and the Safe Harbor Rules

A Deep Dive Into the IRS Form 5741 Attribution Rules, Form 5471 Category of Filers, and the Safe Harbor Rules

Tax Law
 By Anthony Diosdi This article will attempt to explain the attribution rules for stock ownership for individuals and entities regarding the filing requirements of the Form 5471. Form 5471 is used by certain U.S. persons who are officers, directors, or shareholders in respect of certain foreign entities that are classified as corporations for U.S. tax purposes. The Form 5471 and schedules are used to satisfy the reporting requirements of Internal Revenue Code Section 6038 and 6046 along with the applicable regulations.Substantively, Form 5471 backstops various international provisions of the Internal Revenue Code such as Sections 901/904 (Foreign Tax Credit), Section 951(a) (Subpart F and Section 956), Section 951A (GILTI), Section 965 (transition Tax), Section 163(j) (interest deduction limitation), and Section 482 (transfer pricing). International information returns that often are associated…
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