Are Form 1120 Schedule M 3 Deemed 2019-2024

As always, the views expressed during today's event are those of the speakers, not of Strafford, the speaker's firms, or clients, and are not intended to provide legal or tax advice. We've gathered an experienced panel to provide us with a thorough and practical review of the IPU guidance on substantial compliance for Form 5471 information return filings. Our panel today includes Allison Doherty, Director at Aaronson and Rockville, Maryland. She's joined today by Steven Koecher, Steve is with Hawkman Celkon Retik Tasher and Perez in Beverly Hills. Mr. Tasher will be speaking first, so Steve, when you're ready, sir, the audience is all yours. Thank you, Don Allison. Good morning or good afternoon, wherever you are in the audience. It's a pleasure to be here to speak for another Strafford program. We hope we can inform you on this very, very important topic. The title is Section 5471 Compliance Substantial Compliance Rules, but as we go through the material, I think you will see that the analysis could apply to any foreign information reporting. We are in a new era in terms of taxpayer and professional compliance obligations concerning foreign information reporting. I think the new era started seven or eight years ago, and the Internal Revenue Service has been much more focused on foreign compliance, whether it is foreign bank accounts, foreign corporations, or foreign trusts. The focus is much greater today. You could have asked an Internal Revenue Agent seven or eight years ago, maybe not an LB&I agent, but most agents, what is a 5471, and many agents would not know the form or what you were talking about. The same might be true for many tax return preparers or CPAs. The paradigm of what was happening seven or eight years ago, in many instances, a...