The IRS did not finish revising Form 5471
by the April 17 filing deadline, and their systems were not ready to accept electronically filed tax returns containing the repatriation of earnings until after April 2.
Treasury has indicated that it intends to grant limited relief from filing Form 5471
where the foreign corporation is a CFC solely because of downward attribution and no U.S.
, Schedule M, Transactions Between Controlled Foreign Corporation and Shareholders or Other Related Persons
Netherlands $78.8 Luxembourg $54.6 United Kingdom $35.1 Ireland $24.6 Bermuda $21.3 Bahamas $11.6 Canada $10.2 Singapore $8.0 Cayman Islands $7.2 Switzerland $5.7 From Form 5471
, Information Return of U.S.
Partnerships failing to file Form 5471
by the due date are subject to penalties under secs.
If the taxpayer has control over a foreign entity-either incorporated or unincorporated-additional reporting requirements apply: Form 5471
for officers, directors, or shareholders in certain foreign corporations and Form 8865 for certain partners of foreign partnerships (IRC [section]6038 and [section]6046).
Additional attached forms may be required for ownership in a foreign corporation (Form 5471
), passive investment company (Form 8621), and partnership or LLC (Form 8865).
Along with these forms, US citizens must file Form 5471
if they own 10 percent or more of a foreign corporation and Form 926 to report capital contributions to foreign corporations.
Mitchel often hears from distressed Americans who learn all this after the fact, and who must now file IRS Form 5471
along with intrusive requirements for financial statements, disclosures and the risk of $10,000 penalties that can be applied not simply for failure to file but for inadequately filing.
Taxpayers, as well as to see 35% volume increase in delinquent tax and informational filings such as Form 3520: Annual Return to Report Transactions with Foreign Trusts and Receipt of certain foreign Gifts, Form 5471
: Information Return of U.S.
corporation is required by Internal Revenue Service regulations to submit a Form 5471
for any Controlled Foreign Corporation (CFC) with an accounting period ending with or within the U.S.
* If international activities are conducted, either directly or through a partnership or joint venture, have the appropriate international filings occurred, including Form 5471
for ownership of a foreign entry and Form 926 for contributions of capital to a foreign entity?;