Foreign Corporation Reporting (Forms 5471 & 5472)

Set your corporate course with confidence—expert filings for CFC ownership and related-party transactions.

Forms 5471 and 5472

Harness the full power of CFC elections while keeping your filings watertight.

When U.S. persons own or control offshore corporations, Forms 5471 and 5472 demand deep technical know-how. We map your ownership tiers, calculate Subpart F/GILTI inclusions, apply high-tax and QBAI exceptions, and disclose every inter-company flow. Our advisors weave treaty positions and Section 962 strategies into your returns, uncovering opportunities most firms miss.

Frequently Asked Questions

Can you explain the CFC ownership threshold?

A CFC is any foreign entity where U.S. shareholders hold over 50% of vote or value, triggering annual Form 5471 filings.

When is Form 5472 required?

Foreign owners of U.S. solely owned LLCs and corporations with related-party transactions must file Form 5472 to disclose cross-border interactions.

How do you balance Subpart F vs. GILTI inclusions?

We segment tested income, apply QBAI and high-tax carve-outs, and model check-the-box and Section 962 elections for optimal results.

What documentation is needed for Forms 5471/5472?

Provide entity structure, ownership details, financial statements, and summaries of related-party transactions—our organizer and expert CPA/EA will outline every requirement.

What penalties apply for misfilings?

Civil penalties start at $10,000 per form, plus $10,000 per 30-day late period (capped at $50,000); willful breaches risk criminal exposure.

Next Steps

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