What is the $10,000 penalty for failing to file Form 5471?
I am a U.S. person with ownership in a foreign corporation and I also own a foreign LLC that does business in the U.S. I did not file Form 5471 for my foreign corporation. What penalties am I facing and how does Form 5471 relate to my U.S. LLC obligations?
Related Questions
What is the $25,000 penalty for failing to file Form 5472?
I own a single-member LLC as a foreign person and just learned about Form 5472. I never filed it since forming my LLC two years ago. What exactly is the penalty for not filing, and can it really be $2...
How do the $25,000 + $25,000-per-30-day section 6038A penalties for failing to keep records actually work?
I understand the famous $25,000 Form 5472 penalty, but I'm fuzzy on how it stacks when the problem is recordkeeping rather than a missed form, and how the extra per-period penalty kicks in. Is failing...
After Bittner, is the non-willful FBAR penalty per account or per year?
I had several foreign accounts and missed a few years of FBARs. I've read scary things about $10,000 per account adding up fast. Did the Bittner Supreme Court case change that for non-willful cases, a...
What are the penalties for not filing a Beneficial Ownership Information report?
I read that the Corporate Transparency Act requires my foreign-owned LLC to file a Beneficial Ownership Information (BOI) report with FinCEN. What happens if I miss the deadline? I heard the current c...
If I missed Form 5472 two years ago, is the problem only the penalty or is the year still open too?
I am in Australia and my Delaware LLC missed a Form 5472 filing for an earlier year because I did not understand owner-paid expenses counted as reportable transactions. I was mentally treating the iss...
What are the FBAR penalties for non-willful vs. willful violations?
I have a foreign bank account that I use for my LLC business but I never filed an FBAR (FinCEN Form 114). What is the difference between non-willful and willful FBAR penalties? My account balance was ...
We missed Form 3520 for a large foreign gift. Is the penalty really 5% per month?
The gift itself was reported in other family records, but the Form 3520 filing was missed because nobody realized the U.S. recipient had a separate information-return duty. Now we are trying to assess...
I missed Form 5472 last year — how do I avoid the $25,000 penalty?
I formed my foreign-owned US LLC in 2024 but never filed Form 5472 for the 2024 tax year. I just learned this exists and I'm panicking about the $25,000 penalty. I haven't received any notice from the...
After Bittner, is the non-willful FBAR penalty once per year or per account?
I had four foreign accounts under my LLC and missed FBARs for two years. Before, I read the penalty could be per account, which terrified me. Did the Bittner decision change that? If I had four accoun...
Can I use reasonable cause to get Form 5472 penalties removed?
I received a $25,000 penalty notice for not filing Form 5472 for my foreign-owned LLC. My tax preparer in my home country never told me about this form. Can I argue reasonable cause to get the penalty...
Have a similar question?
ForeignLLCTax members get expert answers with IRS citations. One CPA consultation costs $200+. Full access is $9.99/month.
Become a Member — $9.99/moDisclaimer: All content on ForeignLLCTax.com is created by a tax professional and is provided for general educational and informational purposes only. It does not constitute tax, legal, or accounting advice, and should not be relied upon as such. Every tax situation is different — for advice specific to your circumstances, please consult a licensed CPA, Enrolled Agent, or tax attorney. By using this website, purchasing a subscription, or accessing any tools or services, you acknowledge that no client-professional relationship is established between you and ForeignLLCTax.com or its operators. This website is not affiliated with the IRS.
