The US IRS on December 24 released final regulations, TD 9707, under sections 6038A and 6038C of the tax code providing that the Form 5472, “Information Return of a 25% Foreign-Owned U.S. Corporation or a Foreign Corporation Engaged in a U.S. Trade or Business,” must be filed in all cases only with the filer’s income tax return for the taxable year by the due date (including extensions) of that return.
The penalty for failure to timely file is $10,000, with provision for greater penalties if the failure to file continues after IRS notice.
The regulations adopt proposed regulations on the topic (REG-114942-14) without change, and apply as of December 24. See, TD 9707
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