The SIBC team will research and present in person to accountants at RubinBrown about the following topic: When the stock of a US C Corp is sold (use 100% of the shares for our purposes) and the US C Corp owns stock in CFCs (use 100% of the shares for our purposes), what are the Form 5471 filing requirements for both the buyer and the seller?
a. Do both file a stub period 5471?
b. Does one of them file a 5471 for the full year?
c. Who picks up the GILTI/Subpart F income?
d. BONUS: Which foreign jurisdictions require a stub period tax return when there is an
upstream change in ownership?
“RubinBrown presented us with a challenging tax question on which they could not find definitive guidance. The fact that RubinBrown would present us with such a challenging question, speaks to the reputation that SIBC has earned and the confidence in which our clients have in us. In addition to growing in my knowledge of the tax world, this project taught me valuable lessons in project leadership, interpretation and application of complex regulatory guidance, as well as developing strong relationships with clients. These experiences have been invaluable for my professional and personal development. The relationships and mentorship that happen as a result of being a part of SIBC has been a real asset to my experience and development as a rising professional.” - Anselm Friesen
“This project was extremely challenging because we were posed a question that did not have a definitive answer. This taught me that unlike in school, where we are usually taught the answer, we do not always know the answer in the real world. Through this experience, I learned how to synthesize information in order to come to my own conclusion on a matter.” - Dyson Crooker
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