Form 5472 Information Return of a 25% Foreign-Owned U.S. Corporation or a Foreign Corporation Engaged in a U.S. Trade or Business is often an overlooked form. In general, this form has been required if the reporting corporation had a reportable
A Controlled Foreign Corporation (“CFC”) is, in general, a foreign corporation controlled by a U.S. person(s) through ownership of stock. A U.S. person owning at least 10% of a CFC has a reporting requirement for an annual information return of 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 and give insight to taxpayers as to how the IRS will evaluate certain
On December 20, 2006, the Tax Relief and Health Care Act (the “Act”) was enacted. The Act amended Internal Revenue Code § 7632 and established a Whistleblower Office in the IRS which has the responsibility for the administration of the
The Bipartisan Budget Act (“Act”) was signed into law on November 2, 2015 amending the rules concerning how entities taxed as partnerships will be audited by the IRS and who is required to pay the tax resulting from audit adjustments.