Corporate & Cross-Border
Form 5471 (CFC & Foreign Corp Reporting)
Information Return of U.S. Persons With Respect to Certain Foreign Corporations
- Penalty
- $10,000 minimum penalty per form/year. An additional $10,000 for each 30-day period after IRS notice (up to $50,000 max). Criminal penalties apply under IRC §7203.
- Deadline
- Filed with annual income tax return (Form 1040/1120), typically April 15 or October 15 with extension.
- Who must file
- U.S. citizens, green card holders, or U.S. entities who are officers, directors, or shareholders owning 10% or more of voting power/value in a Foreign Corporation (CFC Categories 1–5).
- Statute of limitations
- Statute of limitations remains open indefinitely for the ENTIRE tax return under IRC §6501(c)(8) until Form 5471 is filed.
- Key parts & schedules
- Schedule J (Accumulated E&P) · Schedule P (PTEP Tracking) · Schedule Q (CFC Income) · Schedule I-1 (GILTI Calculation)
Where filings usually fail
- Assuming dormant offshore entities do not require filing
- Failing to track Previously Taxed Earnings & Profits (PTEP) causing double taxation
- Misclassifying Category 4 vs Category 5 filers
How we run it
- Complete earnings & profits (E&P) and tax pool reconstruction
- Subpart F and GILTI inclusion minimization via Section 962 elections
- Statutory disclosure filing with zero statute-of-limitations exposure
Next step
Not sure which forms apply to you?
Describe your situation in three lines. We map the filings before any work starts.