Form 5471 applies to U.S. persons who own stock of foreign corporations. In this session, we look at the rules for determining stock ownership. Stock may be owned directly, indirectly, or constructively. The attribution rules create most of the complexity, and three different sets of attribution rules apply for Form 5471 purposes.
Learning Objectives
• Identify Form 5471 filing requirements
• Determine whether an individual must file Form 5471
Major Topics
• Form 5471
• Form 5471 filing requirements
• Controlled foreign corporation
• Form 5471 attribution rules