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Course Curriculum
1. Form 5471 explained (today)
2. Form 5471 category filers explained. Coming soon
3. Form 5471 instructions Coming soon
4. Modules on Form 5471 schedules e, e-1, g, g-1 (new for 2022!) h, I, m, p, j, q, r.  Coming soon
5. International taxing concepts, check-the-box election Coming soon
6. Tax planning! Coming soon

Form 5471 is kind of insulting to prepare. It is so dense. And seems punitive. But why? In this lesson, Tax Attorney and Form 5471 Specialist Anthony Parent gives his insight into this form so you know exactly the easy mistakes the IRS is looking impose penalties on, and how to think of this form so that you don't become hopelessly depressed in confusion.

What is IRS Form 5471?

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.

The downside of Form 5471

$10,000 penalty for not filing
$10,000 penalty for no “substantial compliance." However, the worry is not for large corporations who deal with LB&I.
No statute of limitations if the IRS feels one was due.
Opens up entire return’s statute of limitation to asses (ASED)
Up to $50,000 continuation penalty

The IRS does not have the staff to review Form 5471 for substantial compliance
The IRS is forced to assess penalties where it is easy. i.e., where no Form 5471 was filed, or mistake was so obvious a new IRS employee with some training but little experience in international experience can see the error.
Very little law on what “substantially complete” means. This IRS does not like to lose.
The IRS prefers slam dunk cases as that is mostly have the brain power to complete.


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