International Tax Lunch: Form 5471: Categories & Attribution Rules Webcast | 4203813A

Date :
May 15, 2020 12:00 PM - 1:00 PM
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Webcast Rebroadcast
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CPE Credits :
CPE 1.00, MCLE 1.00, MCLE LS-TX 1.00
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Foreign shareholders of U.S. corporations must file Form 5471. But how do you know how much stock you own, and indeed if you are even an "owner"? The constructive ownership rules and attribution rules for Form 5471 are complicated, and getting this wrong might mean that you miss a filing requirement. Learn which rules to apply for different categories of Form 5471 filing requirements. Learn how to apply IRC §§318, 6038, and 6046 to find your answers.




* Identify the relevant Code sections for each filing category
* Learn how to apply the attribution and constructive ownership rules for each filing category


Major Subjects:


*Form 5471
*Attribution Rules
*U.S. owner of foreign businesses


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Designed For:

Attorneys, CPAs



Philip D.W. Hodgen, Esq, Esq.
Philip D. W. Hodgen is the principal attorney for HodgenLaw PC, which specializes in the international tax arena. He earned his bachelor’s degree from Claremont McKenna College and his juris doctor degree from the School of Law at the University of California, Los Angeles. He went on to earn a master of laws in taxation from the University of San Diego School of Law. For six years as a youth, he lived in Rhodesia, South Africa and New Zealand. Admitted to the California Bar in 1982, Hodgen spent nine years in law firms and with a large U.S. bank before starting his own firm in 1991. He is a past chair of the International Tax Committee of the State Bar of California’s Tax Section, and was a member of the Executive Committee of the State Bar of California’s Tax Section from 2004-07. He is on the Organizing Committee for CalCPA’s International Tax Conference and its annual Tax Update and Planning Conference. Hodgen frequently speaks on a variety of international tax, trust and estate topics to attorneys, accountants, bankers, and real estate professionals.


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