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Substantially Completed Form 5471 is Required to be Filed

- By : Parag Patel

…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 Announces Increased Enforcement on Form 5471

- By : Parag Patel

…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

- By : Parag Patel

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…

Large Penalties: Form 5471 Information Return of U.S. Persons With Respect to Certain Foreign Corporations

- By : Parag Patel

…$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

- By : Parag Patel

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

- By : Parag Patel

  The reporting requirements for IRS Form 5471 are complex, including ‘category of filer’ and required schedules. However, very few taxpayers know that there are special simplified filing rules for…

Full Analysis of Updated 2012 OVDP Program

- By : Parag Patel

…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

- By : Parag Patel

…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…

2018 ABA COMMENTS ON THE OFFSHORE VOLUNTARY DISCLOSURE PROGRAM AND THE STREAMLINED PROGRAMS

- By : Parag Patel

…filed one or more international information returns, such as Form 5471 (Information Return of U.S. Persons With Respect To Certain Foreign Corporations) or Form 5472 (Information Return of a 25%…

Method to Cure Delinquent or Incomplete Foreign Information Returns Without Penalties

- By : Parag Patel

…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

- By : Parag Patel

…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. Share this: Print More WhatsApp Tweet…

New IRS internal procedure guidance for Streamline Filing Compliance Procedures

- By : Parag Patel

…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 IRS Disclosure Program Announced for Non-Resident Taxpayers: Streamlined Foreign Offshore Procedures

- By : Parag Patel

…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…

New Streamlined Domestic Offshore Procedures (SDOP) is a Game Changer

- By : Parag Patel

…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,…

The Risks of “Opting Out” of OVDI

- By : Parag Patel

…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

- By : Parag Patel

…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

- By : Parag Patel

…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)

- By : Parag Patel

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…

The New IRS Voluntary Disclosure Practice: Not a Good Deal for Noncompliant Taxpayers

- By : Parag Patel

…again present convincing evidence to justify why the willful penalty should not be imposed; Penalties for the failure to file other information returns (such as Form 5471) will not be…

The IRS is Hiring: Expect New Enforcement

- By : Parag Patel

…will be more audits with respect to Forms 5471 (owners of a foreign corporation), 3520/3520A (owners and beneficiaries of foreign trusts), 8621 (PFICs, including foreign mutual funds) and 8865 (owners…

2011 Offshore Voluntary Disclosure Initiative (OVDI)

- By : Parag Patel

…other tax information returns such as Form 5471, Information Return of U.S. Persons With Respect To Certain Foreign Corporations. For additional information, contact Parag Patel of Patel Law Offices at…

IRS Releases FAQs for the Delinquent International Information Return Submission Procedures

- By : Parag Patel

…penalty for the failure to file the delinquent Forms 5471 and 3520 if there are no under-reported tax liabilities and you have not previously been contacted regarding an income tax…

A solution in a tough tax season: the IRS Streamlined Offshore Procedures

- By : Parag Patel

…returns (e.g., Forms 3520, 3520-A, 5471, 5472, 8938, 926, and 8621) for the foreign financial asset; and (4) these failures resulted from non-willful conduct. To be eligible for the streamlined…

Foreign bank account reports (FBARs) and the 2011 Offshore Voluntary Disclosure Initiative (2011 OVDI)

- By : Parag Patel

…income for prior years but did not file FBARs or other information returns related to reporting foreign income and/or assets (e.g., Form 3520 and Form 5471) can file their delinquent…

More Tax Complexity: New Form 8938

- By : Parag Patel

…on Form 3520, Form 3520-A, Form 5471, Form 8621, Form 8865, or Form 8891, you do not need to report the asset on Form 8938. On the Form 8938, however,…

New Extended Deadline for OVDI

- By : Parag Patel

…Account (FBAR), in prior years to report a foreign bank account or signature authority over a foreign bank account owned by an employer. Similar is permitted for delinquent Form 5471,…

Checklist of tax forms for taxpayers with foreign assets

- By : Parag Patel

…this form. Form 5471: Information Return of U.S. Person with Respect to Certain Foreign Corporations — If you’re a shareholder of a Controlled Foreign Corporation (CDC) you must file this…

Instructions for New Streamlined Filing Compliance Procedures for Non-Resident, Non-Filer U.S. Taxpayers

- By : Parag Patel

…information returns (e.g. Form 3520 or 5471), for the past three years and to file delinquent FBARs (Form TD F 90-22.1) for the past six years. Payment for the tax…

Taxpayers’ Evidence of Non-Willfulness or Willfulness Factors

- By : Parag Patel

…information returns, such as a Form 5471? — POAs as substitute for account holder/beneficial owner — full compliance after notification from bank of reporting requirements — actions on closure of…

Below is a List of Common Forms Applicable in Compliance Requirements for U.S. Citizens and Residents with Foreign Assets, Trusts, and Entities

- By : Parag Patel

…and Receipt of Certain Foreign Gifts Foreign Entity Reporting Forms and Disclosures Form 5471 Information Return of U.S. Persons With Respect to Certain Foreign Corporations Form 8865 Return of U.S….