Form 5472 penalties: $25,000 per related party per year, continuation penalties, the reasonable cause standard under Reg. 1.6038A-4, why FTA rarely applies, and the current delinquent filing procedure.
The $25,000 Form 5472 Penalty: How It Stacks, and How Reasonable Cause Abatement Works Read More »
How a foreign person is taxed in the US: 30% on gross FDAP versus graduated rates on net effectively connected income, why the Amazon FBA question is unsettled, and the 18-month rule that can deny every deduction.
Effectively Connected Income: When Does a Foreign Owner Actually Owe U.S. Tax? Read More »
Intercompany pricing must be arm’s length for the IRS and defensible as transaction value for Customs. Why the two conflict, and how contemporaneous documentation prevents a 20-40% penalty.
A foreign-owned US LLC files Form 5472 on a pro forma Form 1120 — only two items completed, no e-filing, and a dedicated IRS address that is easy to get wrong.
Pro Forma Form 1120 for a Foreign-Owned LLC: How the Form 5472 Filing Actually Works Read More »
What each part of Form 5472 asks for, why you file a separate form for every related party, and the omissions that make a return substantially incomplete.
Form 5472 Instructions: How to Complete Each Part Without Triggering the Penalty Read More »
Form 5472 is an information return for foreign-owned US businesses. Who must file, what counts as a reportable transaction, and why the $25,000 penalty repeats every year.