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 Form 5471 2012

2012-2025 Form

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Video instructions and help with filling out and completing Form 5471

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Instructions and help about Form 5471

today we are going to discuss downward attribution and filing of Form 54 71 let's say we have a foreign corporation that is 60% owned by a u.s. individual and 40% owned by a foreign individual the individuals are not related to each other the foreign corporation is more than 50% directly owned by a u.s. person therefore the foreign corporation is a controlled foreign corporation also known as a CFC because the u.s. individual owns at least 10% of the shares of the CFC the u.s. individual is a u.s. shareholder and is a category 5 filer for purposes of form 54 71 the u.s. individual in this case is also a category 4 filer for purposes of forum 54 71 but we are going to mostly focus on category 5 filers in this video let's switch the percentages so that the foreign individual owns 60% and the u.s. individual owns 40% in this case the foreign corporation would not be a CFC or at least it may not be a CFC if the foreign individual happened to own a hundred percent of the sha

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