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What is the attribution rule for 5471?

The Internal Revenue Service (IRS) requires U.S. persons to provide information about foreign corporations using Form 5471, Information Return of U.S. Persons with Respect to Certain Foreign Corporations.

Who needs to file IRS form 5471?

More In Forms and Instructions Certain U.S. citizens and residents who are officers, directors, or shareholders in certain foreign corporations file Form 5471 and schedules to satisfy the reporting requirements of sections 6038 and 6046, and the related regulations.

What is the penalty for filing incorrect 5471?

Form 5471 Penalty and Form 5471 Fine The failure to timely file a Form 5471 (or timely filing a Form 5471, but one which was incorrect or incomplete) is subject to a $10,000 penalty for each year of noncompliance.

What triggers a 5471 filing?

(B) the total value of the stock of such corporation. In summary, Codes statement of the Category 2 filing requirement is simple: If there is a United States person whose stock ownership meets 10 percent (or more) by vote or value, an officer or director must file Form 5471.

What is reasonable cause 5471?

IRS Penalties Form 5471 Reasonable Cause In order to Taxpayers to avoid or dispute these penalties, the filer may make a Reasonable Cause statement submission. If the Taxpayer U.S. person can provide reasonable cause, then the IRS is supposed to waive or abate international reporting penalties.

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