The IRS has issued new (T.D.9667) and proposed (REG-114942-14) regulations concerning the filing of Form 5472, Information Return of a 25% Foreign-Owned U.S. Corporation or a Foreign Corporation Engaged in a U.S. Trade or Business.  New regulations, effective June 6, 2014, adopt temporary and proposed regulations issued in 2011.  Proposed regulations, effective when published in the Federal Register, would require Form 5472 be filed along with the taxpayer’s income tax return, bringing those rules into line with Forms 5471 and 8865.  Penalties may be imposed under section 6038A(d) for failure to file along with the income tax return.

See Sally P. Schreiber, “Regs. Tighten Form 5472 Filing Requirements,” Journal of Accountancy (June 9, 2014)

Posted by David Staggs, Associate Editor, Wealth Strategies Journal