More than ever, it is important that you plan for tax-efficient structures for U.S. subsidiaries of foreign parents - and properly comply with the onerous IRS reporting requirements. This program will evaluate the planning issues and compliance reporting for U.S. subsidiaries of foreign parents, as well as repatriation structures and methods, which rely on the transfer pricing rules. This subject is important for all tax professionals in public practice and in the industry who deal with inbound planning and compliance issues.

Learning Objectives:

• Identify tax-efficient inbound structures to repatriate cash


• Recognize the impact of treaties on repatriation


• Identify tax-advantaged repatriation through aggressive transfer pricing


• Identify the relevant parties for completing a Form 5472


• Complete a sample Form 5472