Search Results for: 5471
New IRS IRM with Updated Streamlined Filing Compliance procedures
…date) has passed together with any required information returns (e.g., Forms 3520, 3520-A, 5471, 5472, 8938, 926, and 8621) even if these information returns would normally not be submitted had…
Foreign bank account reports (FBARs) and the 2011 Offshore Voluntary Disclosure Initiative (2011 OVDI)
…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…
IRS gives widespread penalty relief: ACTION REQUIRED
…The penalty relief also applies to the following information returns if they were not timely filed: Form 5471 (Information Return of U.S. Persons With Respect To Certain Foreign Corporations) and…
IRS Revises Delinquent International Information Return Submission Procedure (DIIRSP)
…Return of Foreign Trust With a U.S. Owner • Form 5471, Information Return of U.S. Persons With Respect to Certain Foreign Corporations • Form 5472, Information Return of a 25%…
New IRS procedures for Streamlined Filing Compliance Procedures for 2017 transition tax filers
…2017, 2018, 2019, and 2020. Taxpayer A separately electronically filed FBARs with FinCEN. Taxpayer A must file Forms 5471 reporting her ownership of Foreign Corp. B, and Taxpayer A must…
Foreign Proprietorship: Form 8858 Filing Requirement
…required to file Form 5471 with respect to a controlled foreign corporation (CFC) and the CFC is the tax owner of a foreign disregarded entity. A U.S. person must file…
Specific Steps for Applying to the IRS Streamlined Foreign Offshore Procedures
…5471, and 8938. In addition, the applicant must file any delinquent FBAR forms for the past six years for which the FBAR filing requirement has passed. In order to ensure…
New Post-OVDP IRS Voluntary Disclosure Procedures Announced
…important. Generally, no other penalties for the failure to file information returns (i.e., Form 5471 penalty, Form 8938 penalty, etc.) will not be automatically imposed. However, non-cooperative taxpayers can have…
Solution: Streamlined Domestic Offshore Procedures
…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…
A solution in a tough tax season: the IRS Streamlined Offshore Procedures
…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…
2011 Offshore Voluntary Disclosure Initiative (OVDI)
…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
…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…
Below is a List of Common Forms Applicable in Compliance Requirements for U.S. Citizens and Residents with Foreign Assets, Trusts, and Entities
…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….
Taxpayers’ Evidence of Non-Willfulness or Willfulness Factors
…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…
Do You Have to Pay US Taxes on Foreign Inheritance?
…on the FBAR and FATCA 8938 form. Foreign Business Ownership – Inheriting ownership of a foreign business has significant U.S. tax reporting obligations. Extensive reporting on Form 5471 extends deep into…
Instructions for New Streamlined Filing Compliance Procedures for Non-Resident, Non-Filer U.S. Taxpayers
…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…
Details of the Delinquent International Information Return Submission Procedures (DIIRSP)
…to Report Transactions with Foreign Trusts & Receipt of Foreign Gifts • Form 3520-A, Annual Information Return of Foreign Trust With a U.S. Owner • Form 5471, Information Return of…
Checklist of tax forms for taxpayers with foreign assets
…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…
More Tax Complexity: New Form 8938
…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,…
The New IRS Voluntary Disclosure Practice: Not a Good Deal for Noncompliant Taxpayers
…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
…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…