Content Provider
Rimon logo
Handout Materials
Presentation Slides
Additional Materials
Webinar Technical FAQs
Free cpece webinars
Handling an International Tax Assessment: Form 5471

HANDLING AN INTERNATIONAL TAX ASSESSMENT: FORM 5471

Cost Free
Presentation Length 1.0 hour

Recorded DateOctober 23, 2024
CPE:Not available
(archived webinars do not offer CPE credits)
Subject AreaTaxes
Course LevelBasic
Course Description

The Internal Revenue Service has increasingly sought to assess penalties against taxpayers who have previously failed to file required information forms. One of the most commonly required forms - and one of the forms most often the subject of penalty assessment - is Form 5471, required for specified stakeholders in foreign corporations.

This program details Form 5471 requirements and assessable penalties - including automatic extensions of Statute of Limitations periods. We'll cover in detail how to best combat penalty assessment and options for penalty mitigation.

Learning Objectives:


  • Outline Form 5471

  • Recognize automatic extensions of Statute of Limitations periods

  • Determine how to best combat penalty assessment and options for penalty mitigation

Not logged
PLEASE NOTE: ARCHIVED WEBINARS DO NOT QUALIFY FOR CPE
Linkedin
Rimon logo

Patrick McCormick is an attorney with over a dozen years of experience, focusing his practice specifically on international taxation. Mr. McCormick represents both business and individual clients on all aspects of United States international tax rules, both from an income tax and estate/gift tax perspective. Having previously served as a partner at a large law firm, a midsized accounting firm, and a boutique tax law firm, Patrick’s client exposures have covered every conceivable area of American-side international tax matters. Patrick has also represented every type of taxpayer – from multibillion-dollar business enterprises and ultra-high net worth individuals to startups and individuals with complex questions but limited budgets.

Mr. McCormick has worked with clients located in over 90 countries on American tax considerations of multinational activities, cultivating specialized knowledge in every area of United States international tax rules. His explicit practice focus has facilitated an unparalleled expertise in the field; Patrick is trusted by clients and advisors around the world to obtain optimal results on international tax matters.

Mr. McCormick is a primary and prolific authority on tax matters. He has spoken on all aspects of international tax to hundreds of thousands of attendees around the globe, functioning as the primary international tax resource for national organizations including CPAacademy.org, Strafford, Lawline, and Leimberg Information Services. Patrick has presented for the American Bar Association, the American Immigration Law Association, and state and local bar associations around the United States. He is a regular contributor to America’s premier tax law publications, including Tax Notes, Journal of Taxation, Tax Notes International, Law360, and Practical Tax Lawyer.

Mr. McCormick published his first treatise on international tax matters, Allocation and Apportionment Rules Under Secs. 861-865, for Thomson Reuters’ Catalyst platform, in October 2021. In late 2021, he also released a 15-hour digital course entirely dedicated to nonresident taxation, United States Tax Considerations for Nonresident Taxpayers. Mr. McCormick has been named a Super Lawyers Rising Star from 2016-2022.
 

About Our Presenter

Rimon logo
Rimon is a highly selective entrepreneurial firm that combines the dynamic client service, teamwork, and agility of a high-end boutique law firm with the deep multidisciplinary experience of a large global firm. Our clients consistently receive exceptional representation across twelve countries and five continents, from our all-star team of corporate, litigation, tax, intellectual property, entertainment, and private client attorneys.

Rimon's consistent excellence, commitment to the community, and innovation have been internationally recognized, including by Harvard Law School, Stanford Law School, Chambers, Best Lawyers, Super Lawyers, the Financial Times Innovation awards, the Atlantic, the American Bar Association's Legal Rebels, the Economist, the Recorder, and many more.

Rimon’s clients range from cutting-edge technology startups to financial institutions and Fortune 100 companies.

Rimon's attorneys come with decades of experience before even joining Rimon. Rimon's attorneys were meticulously drawn from the top ranks of premier law firms, international corporations, and academia. They hold JDs, PhDs, LLMs, and MBAs from the best universities in the United States and abroad. They have worked on multi-billion dollar deals, have won bet-the-company litigation, and have run universities. Their experience and education ensure our clients receive consistently excellent and comprehensive counsel.