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Form 5471 Basics

Everything you need to know about foreign corporation reporting to avoid problems.

The Top Form 5471 Reporting Mistakes to Avoid

There are many common errors in foreign corporation reporting that can be avoided.

Correcting Common Form 5471 Errors

The US government has 5 solutions to correct Form 5471 errors.

Frequently Asked Form 5471 Questions

The most frequently asked questions about Form 5471 and filing.

Meet Mr. Patel

Mr. Patel’s expertise is in all stages of tax controversies including international tax law, foreign bank accounts and disclosures, tax audit defense, and tax appeals. Mr. Patel has counseled over 1000 voluntary tax matters for assets before the US Internal Revenue Service.

Mr. Patel is a graduate of Georgetown (J.D.) and New York University (LL.M tax) law schools, which are the top 2 tax law schools in the United States. Mr. Patel is a Board Certified Tax Law Attorney, Board Certified Estate Planning Law Specialist, Board Certified Elder Law Attorney, and frequent speaker on legal issues affecting tax, offshore tax planning, and estate planning.

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About Us

Patel Law Offices’ goal is to achieve our clients’ objectives in the most creative, responsive, and cost-effective manner.

Our International Tax Attorney team represents clients nationwide and globally in IRS offshore and voluntary disclosure solutions.  We have counseled clients in over 1000 voluntary disclosure matters and are one of the most experienced IRS offshore and voluntary disclosure law firms.

Each case is led by Mr. Patel, who is a Board Certified Tax Law Lawyer. Our International Tax Attorney team concentrates in IRS offshore and voluntary disclosure solutions for undisclosed accounts, assets and investments including Streamlined Domestic Offshore Procedures (SDOP), Streamlined Foreign Offshore Procedures (SFOP), Voluntary Disclosure Practice (VDP), Delinquent International Information Return Submission Procedure (DIIRSP), Delinquent FBAR Submission Procedure (DFSP).

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Latest Blog Posts

New Mandatory E-filing Form 8300 for Reporting of Large Cash Currency Transactions


The IRS announced yesterday that certain businesses that receive payments of over $10,000 in cash must file Form 8300, Report of Cash Payments Over $10,000 Received in a Trade or Business, electronically starting in 2024, the IRS said in a news release (IR-2023-157). This new requirement applies to businesses that are required to …

IRS Uses New Funding to Target US Persons with Malta Accounts


The US Treasury and US Internal Revenue Service are to leverage more resources to detect Americans using Malta personal pension accounts to claim tax exempt income, it said in a statement last week. The additional resources to investigate the Malta schemes will come from the Inflation Reduction Act, the Treasury sai…

NJ Contractor Charged with Criminal Tax Evasion for Unreported Checks


A Union County NJ contractor was arrested last week for tax evasion for not reporting cashed check income. Joel Konopka, 45, of Elizabeth, New Jersey, is charged by indictment with four counts of corporate tax evasion, two counts of filing false corporate tax returns, and two counts of failing to file corp…

Beware the New 2023 Form 1099-K


Beginning in 2023, third-party payment networks must file Form 1099-K with the IRS and provide a copy to the taxpayer when the gross payment amount exceeds $600. However, not all payments from third parties are taxable. Taxpayers can take steps to prevent non-taxable items from being reported. They also can remedy a third-party payment re…

Common Problems Solved

Streamlined Domestic Offshore Procedures (SDOP)

The Streamlined Domestic Offshore Procedures is one of the two popular programs available under the IRS Streamlined Filing Compliance Procedures. It is for U.S. Resident Taxpayers who originally filed income tax returns, but were non-willful in not reporting foreign accounts, investments or income, who can use Form 14654 Certification by U.S. Person Residing in the U.S. to become compliant. This limited tax amnesty solution for U.S. resident taxpayers holding noncompliant foreign accounts has a reduced single year 5% offshore penalty. Our legal team has advised and prepared hundreds of Streamlined cases with the IRS.

Streamlined Foreign Offshore Procedures (SFOP)

The Streamlined Foreign Offshore Procedures is one of the two popular programs available under the IRS Streamlined Filing Compliance Procedures. Applicants need not have filed original tax returns, but they must be non-willful in not reporting foreign accounts, investments or income, via Form 14653 Certification by U.S. Person Residing Outside of the U.S. to become compliant. This limited tax amnesty solution for U.S. non-resident taxpayers holding noncompliant foreign accounts has a 0% penalty. Our legal team has advised and prepared hundreds of Streamlined cases with the IRS.

Delinquent International Informational Return Submission Procedures (DIIRSP)

The DIIRSP is one of the four methods for taxpayers with unreported offshore accounts to become compliant. Taxpayers who have failed to file certain international-related information returns including Forms 5471, 8938, 3520, 8865, 926, 5472, an 8858 can use the DIIRSP to cure the non-compliance. No penalties are applied if there is reasonable cause for the failure to file the information form and the IRS agrees. Reasonable Cause is a fact specific submission, which is based on each applicant's facts and circumstances.

Delinquent FBAR Submission Procedure (DFSP)

The FBAR is the FinCEN Form 114, which is commonly misunderstood. A delinquent or late FBAR is subject to very high penalties. The DFSP is one of the four methods for taxpayers with unreported offshore accounts to become compliant. Taxpayers who have failed to an FBAR can use the DFSP to cure the non-compliance. While there is no DFSP penalty the DFSP has complex rigid eligibility requirements. Our legal team mitigates foreign account FBAR mistakes for clients around the globe.

Form 8938 Penalties

A delinquent or late Form 8938 Statement of Foreign Financial Assets is subject to many common mistakes and high penalties. Our legal team cures many common Form 8938 errors for clients around the globe.

Form 5471 Penalties

U.S. owners and investors of certain foreign corporations must file a Form 5471, otherwise there are very high Form 5471 Penalties. Form 5471 is a complex form with many common mistakes. because of the expansive disclosure of corporation's assets, liabilities and equity. Our legal team can help you fix late or unfiled Form 5471 errors.

Malta Pension Plan Problems

Malta Pension Plans have been criminally and civilly investigated by the IRS and are on the IRS "dirty dozen" list. Recently in late 2021, the United States and Malta entered an agreement regarding Malta pension rollovers. We have assisted dozens of taxpayers with compliance and solutions with Malta Pension Plan problems.

Form 3520 Penalties

U.S. persons connected to foreign trusts or US recipients of foreign gifts must file a Form 3520, otherwise there are very high Form 3520 penalties. Form 3520 is a complex form with many common mistakes. Our legal team can help you fix late or unfiled Form 3520 errors.