Connect with us

Global Banking and Finance Review is an online platform offering news, analysis, and opinion on the latest trends, developments, and innovations in the banking and finance industry worldwide. The platform covers a diverse range of topics, including banking, insurance, investment, wealth management, fintech, and regulatory issues. The website publishes news, press releases, opinion and advertorials on various financial organizations, products and services which are commissioned from various Companies, Organizations, PR agencies, Bloggers etc. These commissioned articles are commercial in nature. This is not to be considered as financial advice and should be considered only for information purposes. It does not reflect the views or opinion of our website and is not to be considered an endorsement or a recommendation. We cannot guarantee the accuracy or applicability of any information provided with respect to your individual or personal circumstances. Please seek Professional advice from a qualified professional before making any financial decisions. We link to various third-party websites, affiliate sales networks, and to our advertising partners websites. When you view or click on certain links available on our articles, our partners may compensate us for displaying the content to you or make a purchase or fill a form. This will not incur any additional charges to you. To make things simpler for you to identity or distinguish advertised or sponsored articles or links, you may consider all articles or links hosted on our site as a commercial article placement. We will not be responsible for any loss you may suffer as a result of any omission or inaccuracy on the website. .

Top Stories



To Certain Taxpayers Required to File Controlled Foreign Corporation Information Returns

  • IRS Notice 2018-13 provided welcome relief to certain U.S. shareholders of CFCs from requirement to file Form 5471
  • Other U.S. taxpayers may not realize failure to file for tax year 2017 and future years will trigger $10,000 IRS penalty

The American Institute of CPAs (AICPA) today urged the Internal Revenue Service (IRS) to immediately provide prospective penalty relief to any first-time filer of Form 5471, Information Return of U.S. Persons with Respect to Certain Foreign Corporations, whose filing obligation results solely from the imposition of “downward attribution” created by the provisions of Public Law No. 115-97, commonly referred to as the Tax Cuts and Jobs Act (the “Act”).  “Downward attribution” permits stock owned by a foreign person to be attributed to a United States person for purposes of creating a Controlled Foreign Corporation (CFC).

The AICPA explained in its letter that IRS Notice 2018-13 eliminated the requirement for certain United States shareholders of CFCs to file a Form 5471.  The relief was a “welcome acknowledgement of the unnecessary burden otherwise imposed on many taxpayers” by the Act’s repeal of Internal Revenue Code section 958(b)(4), the AICPA wrote.

However, the AICPA stated, “Many other taxpayers will face a new requirement to file Form 5471 without realizing it.”  The exception for filing Form 5471 granted by Notice 2018-13 does not apply to an unrelated third party who is a U.S. person and who owns stock in a CFC.  Those taxpayers need immediate prospective penalty relief because the requirement to file Form 5471 applies to tax year 2017, as well as all future years, the AICPA wrote.

“Failure to timely file Form 5471 results in immediate imposition of a $10,000 penalty by the IRS,” the AICPA wrote.  “Taxpayers have historically faced difficulties in having this penalty abated, even when taxpayers believed they had reasonable cause,” the AICPA noted.

Global Banking & Finance Review


Why waste money on news and opinions when you can access them for free?

Take advantage of our newsletter subscription and stay informed on the go!

By submitting this form, you are consenting to receive marketing emails from: Global Banking & Finance Review │ Banking │ Finance │ Technology. You can revoke your consent to receive emails at any time by using the SafeUnsubscribe® link, found at the bottom of every email. Emails are serviced by Constant Contact

Recent Post