188bet亚洲真人体育下载 urges IRS to provide prospective penalty relief to certain taxpayers required to file controlled foreign corporation information returns

的 American Institute of CPAs (188bet亚洲真人体育下载) today urged the Internal Revenue Service (IRS) to immediately provide prospective penalty relief to any first-time filer of Form 5471, U信息返回.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 减税和就业法案 (“法”).  “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).

的 188bet亚洲真人体育下载 explained in its 信 that IRS Notice 2018-13 eliminated the requirement for certain United States shareholders of CFCs to file a Form 5471.  的 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), 美国注册188bet亚洲真人体育下载写道. 

然而, 美国注册188bet亚洲真人体育下载表示, “Many other taxpayers will face a new requirement to file Form 5471 without realizing it.”  的 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, 美国注册188bet亚洲真人体育下载写道.  

“Failure to timely file Form 5471 results in immediate imposition of a $10,美国国税局的罚款,美国注册188bet亚洲真人体育下载写道.  “税payers have historically faced difficulties in having this penalty abated, even when taxpayers believed they had reasonable cause,美国注册188bet亚洲真人体育下载指出.