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    Form 5471 Penalties

    Article This item discusses the importance of timely filing federal income tax returns that include Form 5471, regardless of whether the return shows a balance due, because of the extensive penalties for failure to comply with the reporting requirements
    Published on June 16, 2011

    Tips for Preparing the Form 5471 for Controlled Foreign Corporations

    Article This article gives an overview of the issues faced by practitioners when preparing Form 5471 and can serve as a roadmap to the potential problems and traps for the unwary
    Published on January 28, 2011

    IRS Crackdown on Form 5471 A Sign of Things to Come

    Article ...IRS began sending "soft" letters to corporate taxpayers warning that beginning in 2009, the Service would automatically assert penalties on any late-filed Forms 1120 that include a Form 5471
    Published on January 28, 2011

    Automatic Penalties for Late Forms 5471 and Related Forms

    Article The IRS has begun informing taxpayers that starting January 1, 2009, it will automatically assess Sec. 6038 penalties for each late-filed Form 5471
    Published on June 01, 2010

    Automatic Penalty Assertions Begin for Delinquent Forms 5471

    Article In August 2008, the IRS began mailing “soft letters” to corporations that had, during the past two years, filed a late Form 1120 that included at least one Form 5471, to inform them of the new automatic penalty assertion procedures
    Published on April 19, 2010

    Penalty Relief for Delinquent FBARs and Forms 5471 Ends August 31

    Article The IRS has provided penalty relief in guidance related to its latest offshore voluntary disclosure initiative. The focus of this item is on who qualifies for penalty relief and procedures for obtaining this relief.
    Published on June 30, 2011

    IRS Changes Policy for Asserting Penalties for Late-Filed Form 5471

    Article The IRS recently sent letters to certain corporate taxpayers advising them that effective January 1, 2009, penalties for late-filed Forms 5471 will automatically be asserted when such forms are attached to a late-filed Form 1120
    Published on April 19, 2010

    When Is a Foreign Entity Relevant for U.S. Entity Classification Purposes

    Article A company organized under the laws of a foreign country that does not conduct business in the United States still may be “relevant” for purposes of U.S. taxation. Therefore, it may be necessary to select a federal tax classification to minimize U.S. tax.
    Published on May 14, 2010

    IRS Provides Guidance on Return Preparer Penalties

    Article The IRS has provided guidance (Notice 2008-46) on the implementation of the  return preparer penalties under Sec. 6694.
    Published on May 12, 2010

    Delinquent U.S. Foreign Information Returns Is Filing Under the 2011 OVDI Appropriate

    Article This item explains the process by which taxpayers may take advantage of an opportunity to avoid a substantial portion of the penalties that would otherwise be due on previously unreported offshore accounts, entities, and income.
    Published on January 13, 2012

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