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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).

Reviews

Nicholas Visco ★★★★★

Extremely knowledgeable and well versed in probate matter. Mr. Patel and his team have been excellent to work with.

navnit patel ★★★★★

Parag Patel is an excellent tax lawyer. He is a very approachable and answers all questions in detail and in a way that is easy to understand. If you have any offshore tax issues he is the guy you want to talk to. Highly recommended by me and my family.

Latest Blog Posts

Are Trusts Required to Report under the Corporate Transparency Act (CTA)?


Generally, the answer is no. Starting January 1, 2024, the Corporate Transparency Act (CTA) will require most U.S. corporations, LLCs, and other legal entities formed through state filings or foreign entities registered to do business in the U.S. (“Reporting Company”) to file a Beneficial Ownership Information (BOI) report with the Financial Crimes E…

Is First-Time Abatement Applicable In International Penalty Cases?


The Internal Revenue Service (IRS) issued a memorandum from John E. Hinding, the Director of Specialized Examination Programs & Referrals, regarding penalty abatements for Forms 5471 and 5472. The memo was addressed to IRS Independent Office of Appeals employees focusing on international penalties and provides updated guidance regarding the appeals procedures…

National Taxpayer Advocate calls IRS Penalties Draconian and Inefficient


National Taxpayer Advocate Erin Collins recently issued her 2023 Annual Report to Congress. By law, the Advocate’s report is required to identify the 10 most serious problems taxpayers are experiencing in their dealings with the IRS and to make administrative and legislative recommendations to address those problems. Most Serious Problem #8 is that…

Crypto is not = Cash currency for IRS reporting


The IRS released Announcement 2024-4, providing transitional guidance under section 6050I with respect to reporting transactions involving the receipt of digital currency. Generally, when receiving more than $10,000, IRS reporting is required. The announcement clarifies that, at this time, digital assets are not required to be included when determining whether cash received…

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.