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
*U.S. owner of foreign businesses