Search Results for: 5471
Substantially Completed Form 5471 is Required to be Filed
…Background on Form 5471. Certain U.S. persons, who are officers, directors, or shareholders in certain foreign corporations are required to file Form 5471. The form and schedules are used to…
IRS Provides Form 5471 Information-Filing Relief For Dormant Foreign Corps.
…5471 with respect to dormant foreign corporations described in section 3 below. Persons complying with this revenue procedure satisfy their Form 5471 filing obligations under sections 6038(a)(1), 6038(a)(4), and 6046(a)(3)…
IRS Announces Increased Enforcement on Form 5471
…Forms 5471 by US shareholders of controlled foreign corporations (CFCs) rather than attaching the form to the accompanying tax returns, so-called “loose-filed Forms 5471.” The loose-filed Form 5471 campaign seeks…
The IRS Large Business and International division (LB&I) has announced a new Loose Filed Forms 5471 compliance enforcement campaign
The new Loose Filed Forms 5471 targeted enforcement campaign was identified through LB&I data analysis and suggestions from IRS employees. IRS employees likely received many Loose Filed Forms 5471 that…
Penalty relief for International Information Forms 5471, 5472, and 8865
US tax law imposes large penalties for the failure to timely file international information returns on Form 5471, Information Return of U.S. Persons With Respect to Certain Foreign Corporations; Form…
Tax Court Rules IRS Cannot Assess or Collect Form 5471 Penalties
…(Code) Section 6038(b) for a late-filed Form 5471 against Alon Farhy. This is a big win for taxpayers because the IRS automatically assesses these penalties on any late-filed Form 5471,…
Large Penalties: Form 5471 Information Return of U.S. Persons With Respect to Certain Foreign Corporations
…$10,000 for each Form 5471 that is filed after the due date of the associated income tax return, including any extensions. Penalties on late-filed Forms 5471 are systemically assessed, resulting…
Delinquent or unfiled IRS Form 5471
IRS Form 5471 is a form required to be filed by US owners of foreign corporations. The form and filing requirements are complicated, and the penalties and consequences for non-filing…
Complicated Form 5471 filing requirements simplified for dormant foreign corporations
…basic information and the top 12 Form 5471 most common errors to avoid. Currently, the US government has 5 solutions to correct many Form 5471 errors. If you have any…
Dormant foreign corporations not subject to complicated Form 5471 filing requirements
…for Dormant Foreign Corporation’. We have compiled Form 5471 basic information and the top 12 Form 5471 most common errors to avoid. Currently, the US government has 5 solutions to…
New Webinar: Resolving International Tax Compliance Disputes: FBAR Controversy, Penalties, Appeals, Form 3520/3520-A, Form 5471
I am pleased to announce that I will be speaking in an upcoming Strafford live video webinar, “Resolving International Tax Compliance Disputes: FBAR Controversy, Penalties, Appeals, Form 3520/3520-A, Form 5471”…
Automatic Form 5471 and 5472 Penalties in Spotlight by 2020 National Taxpayer Advocate Report
…and to make administrative and legislative recommendations to mitigate those problems. Among the “most serious problems” addressed is the IRS’s treatment of Form 5471/5472 §§ 6038 and 6038A foreign information…
IRS International Fines Not Excessive: Form 3520 Penalties Upheld, Form 5471 Penalties Again Unassessable
…procedural errors by the IRS and constitutional arguments. In Mukhi v. Commissioner of Internal Revenue, the taxpayer challenged substantial civil penalties imposed for failing to file required forms (Forms 5471,…
Forms 3520, 5471 and 5472 Penalty Relief
…information returns if they were not timely filed: Form 5471 (Information Return of U.S. Persons With Respect To Certain Foreign Corporations) and Form 5472 (Information Return of a 25% Foreign-Owned…
Forms 5471, 5472, 3520 Partial Penalty Relief Still Available for 2019 and 2020 Returns
IRS Notice 2022-36 provided relief for certain taxpayers from certain failure to file penalties and certain international information return penalties with respect to tax returns for tax years 2019 and…
Full Analysis of Updated 2012 OVDP Program
…but failed to file certain information returns, such as Form 5471, Information Return of U.S. Persons With Respect to Certain Foreign Corporations, and Treasury Form TD F 90-22.1, Report of…
New IRS practice unit: “Substantial compliance” doctrine, international information return penalties
…particularly Form 5471. The IRS recently released a new International Practice Unit (“IPU”) on failures to file form 5471. IPUs are meant to act as a guide for IRS examiners…
Is First-Time Abatement Applicable In International Penalty Cases?
…FTA penalty relief can also extend to international situations. Changes To FTA Penalty Relief For Forms 5471 and 5471 The memorandum establishes a procedural change to the Internal Revenue Manuals,…
2018 ABA COMMENTS ON THE OFFSHORE VOLUNTARY DISCLOSURE PROGRAM AND THE STREAMLINED PROGRAMS
…Form 5471 (Information Return of U.S. Persons With Respect To Certain Foreign Corporations) or Form 5472 (Information Return of a 25% Foreign-Owned U.S. Corporation or a Foreign Corporation Engaged in…
Method to Cure Delinquent or Incomplete Foreign Information Returns Without Penalties
…amount. • The penalty for failure to file Form 5471, 8865, or 8858 (information returns of U.S. persons with respect to foreign corporations, partnerships, and disregarded entities) is $10,000 plus…
Protective Filing of Information Returns
…a taxpayer is required to file Form 5471 and fails to do so, the failure to file penalty can be $10,000 for each year for each Form 5471 not filed….
New IRS internal procedure guidance for Streamline Filing Compliance Procedures
…is a combination of all years filed. For example submissions containing 3 Forms 5471 for 2011 and 3 Forms 5471 for 2012 would be referred since the total is 6….
New Streamlined Domestic Offshore Procedures (SDOP) is a Game Changer
…U.S. law, and may have failed to file an FBAR (FinCEN Form 114, previously Form TD F 90-22.1) and/or one or more international information returns (e.g., Forms 3520, 3520-A, 5471,…
New IRS Disclosure Program Announced for Non-Resident Taxpayers: Streamlined Foreign Offshore Procedures
…file delinquent or amended tax returns, together with all required information returns (e.g., Forms 3520, 5471, and 8938) and (2) for each of the most recent 6 years for which…
How to Fix an Erroneous Filed Tax Return without Penalties
…Form 5471 or 8938) but fails to do so, a superseding return can be used to rectify the error. If a taxpayer catches the omission of Form 5471 after filing…
IRS Warning Letter Warns Foreign Business Owners About Section 965 Transition Tax Enforcement
…clients who previously filed Form 5471, which indicates to the IRS that the individual owns a foreign corporation and may have had an obligation to pay transition tax for the…
The Risks of “Opting Out” of OVDI
…to file a substantially complete Form 5471, Controlled Foreign Corporation Return in accordance with Treas. Reg. §1-6038-2(k). Under Code section 6038(b) the taxpayer has the burden of showing that the…
Caution: Foreign Businesses Require Additional Reporting
…CFCs are subject to potentially complex U.S. tax reporting requirements and, at a minimum, must file U.S. tax Form 5471 every year, whether or not the business is profitable. Even…
Beware of Overlooked Common Overseas Tax Forms
…8832, you may be required to file Form 8858 if the entity is disregarded; Form 5471 if the entity is classified as a corporation; or Form 8865 if classified as…
The Misunderstood Extension of time to file FinCEN Form 114, Report of Foreign Bank and Financial Accounts (FBAR)
…5471 (Information Return of U.S. Persons With Respect to Certain Foreign Corporations), IRS Form 8865 (Return of U.S. Persons With Respect to Certain Foreign Partnerships) and IRS Form 8621 (Information…