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Guide to IRS International Penalties

Taxpayer -These are applied to each tax year with no statue of limitation
Filing Requirement
Form
IRC Penalty section
U.S. person with interest in:
Foreign Corporation (FC)
Form 5471
IRC 6038(b)
Foreign Partnership (FP)
Form 8865
FC or FP with Foreign Disregarded Entity
Form 8858
Penalty reducing Foreign Tax Credit:
Foreign Corporation (FC)
Form 5471


IRC 6038(c)

Foreign Partnership (FP)
Form 8865
FC or FP with Foreign Disregarded Entity***
Form 8858
25 percent foreign-owned U.S. corporations
Form 5472
IRC 6038A(d)
25 percent foreign-owned U.S. corporations that fail to: 1) authorize the reporting corporation to act as agent of a foreign related party, or 2) substantially comply with a summons for information
N/A
IRC 6038A(e)
Transferor of certain property to foreign persons:
Foreign Corporation
Form 926


IRC 6038B(c)

Foreign Partnership
Form 8865 Schedule O
Foreign corporations engaged in U.S. business
Form 5472
IRC 6038C(c)
Individuals receiving gifts from foreign sources exceeding $10,000 (adjusted annually for cost of living)*** use to be $100,000
Form 3520
IRC 6039F(c),
Individuals that relinquish their U.S. citizenship or abandon their long-term resident status
Form 8854
IRC 6039G(c)
Foreign persons holding direct investments in U.S. real property interests
N/A
IRC 6652(f)
U.S. person who transfers to, or receives a distribution from, a foreign trust
Form 3520
IRC 6677(a)
U.S. Owner of a foreign trust
Form 3520-A
IRC 6677(b)
Failure to file returns with respect to acquisitions of interests in:
Foreign Corporation
Form 5471 Schedule O


IRC 6679,

Foreign Partnership
Form 8865 Schedule P
IRC 6679,
Foreign corporation failure to file personal holding company tax return
Form 1120 Schedule PH
IRC 6683(Repealedin 2005)
DISC, IC-DISC, or FSC failure to file returns or supply information:
DISC
Form 1120-DISC


IC-DISC
Form 1120-IC-DISC
FSC
Form 1120-FSC
Allocation of Individual Income Tax to Guam or the CMNI
Form 5074
IRC 6688
Statement for Individuals Who Begin or End Bona Fide Residence in a U.S. Possession
Form 8898
IRC 6688
Taxpayer’s failure to file notice of foreign tax redetermination under IRC 905(c) or IRC 404A(g)(2)
Form 1116 or Form 1118 (attached to Form 1040-X or Form 1120-X)
IRC 6689
Taxpayer’s failure to file notice of foreign deferred compensation plan under IRC 404A(g)(2)
N/A
IRC 6689
Taxpayer’s failure to disclose treaty-based return position
Form 8833 or statement
IRC 6712
Failure to Provide Information Concerning Resident Status (Passports and Immigration)
N/A
IRC 6039E
Information with Respect to Foreign Financial Assets Yearly penalty
Form 8938, Form TDF90.22-1
IRC 6038D
50% of assets

Read more at: Tax Times blog

 
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