Flow of International reorting Through the Form 1120

1. Compliance Aspects of the Forms 1118 and 5471 North American International Tax Conference Edward Umling CPA, LLM December 7, 2009 0

2. 1 Form 1118 — Foreign Tax Credits — Corporations This form is not mandatory. It is used to claim a credit for income taxes paid to a foreign country on which U.S. taxes are also paid on the same income. You have up to 10 years to file this form!

3. Form 5471 — Information return of US Persons — Certain Foreign Corporations Form 5471 is used by certain U.S. citizens and residents who are officers, directors, or shareholders in certain foreign corporations. The form and schedules are used to satisfy the reporting requirements of I.R.C. § 6038 and 6046. Form 5471 is due when your income tax return is due, including extensions. Attach Form 5471 and schedules to your income tax return. 2

4. Form Overview 3

5. 4 17,337,549 to Schedule C line 13 This number may carry to page 2 11,717,690 to Schedule C line 15 To 1120 page 1 line 7 To 1120 page 1 line 10 From 1118 Page 3 Part I

6. 5 2 possible entries: either the schedule J part 1 line 11 or, amount from 1118 page 1 column 13 From 1118 page 3 part 1 column 10 43,520,504 From the 1120 page 1 line 30 .558 15,230,420 To 1120 page 3 schedule J line 5a From 5471 Schedule E From the 1120 page 3 Schedule J line 4

7. 6 From 1118 page 4 Part 1 column 7 To 1118 page 2 Schedule B From 5471 To 1118 page 1 Schedule A

8. 7 To Page 3 Schedule C Column 6b From 5471 page 4 Schedule I

9. 8 From 1118 Page 1 Columns (2a+2b+3a+3b) From 1118 Page 1 column 5 From 1118 Page 1 column 7

10. 9 To Form 1118 Page 2 Line 7a From 1120 Page 3 Schedule J line 10

11. 10 From 1118 Page 1 Column2a and 3a From 1118 page 1 column 2b and 3b Schedule M-3 Item To page 1 line 4

12. 11 From the 1118 page 2 part II line 5 Calculated Tax To 1118 page 2 part II line 9 To 1120 page 1 line 31

13. *WARNING* This schedule is functional currency only! 14,390,165 Local Currency Number relates to translated amounts on 1118 page 1 schedule A 14,390,165 /.83 =17,337,549

14. Actual Taxes Paid To Form 1118 page 2 Schedule B Column (h)

15. Amount carries to 1118 page 1 Schedule A (192,014 * .97740 ) = 187,675 3,250,000 To 1118 page 4 schedule D

16. Debrief 15  Dividends must reconcile Other income items must reconcile Tax liability must reconcile Foreign reporting must tie-out   

17. The informal comments and the information presented in these slides should not be construed as constituting tax advice applicable to any specific taxpayer because each taxpayer’s facts are different To ensure compliance with requirements imposed by the IRS, we inform you that any U.S. tax advice mentioned in the presentation or contained in these slides is not intended or written to be used, and cannot be used, for the purpose of (i) avoiding penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending to another party any transactions or matters addressed herein. If you have any questions please contact Edward Umling, Parente Randolph, LLCPhone (412) 697-6427, email: eumling@parentenet.com

18. Thank You for Attending The Conference Edward Umling CPA, LLM 412-391-1994 Ext 259 eumling@urishpopeck.com