Tag: IRS Assessed Foreign Information Reporting Penalties

By Anthony Diosdi Penalties for failing to timely file foreign information returns such as Form 3520, Form 5471, and Form 5472 with the Internal Revenue Service or IRS can be serious. Penalties for failing to timely file a foreign information return can range from a minimum of $10,000 to several million dollars. The authority to assess most international penalties can be found in Sections 6038 and 6039 of the Internal Revenue Code. Originally, these penalties were assessed manually against taxpayers during an audit. However, beginning January 1, 2009, the IRS began systematically assessing monetary penalties for failing to disclose interests in offshore/foreign assets and holdings on a foreign information return. The IRS treats international penalties as summarily assessable, as they are not subject to deficiency procedures, wherein individuals receive a…

By Anthony Diosdi Penalties for failing to timely file foreign information returns such as Form 3520, Form 5471, and Form 5472 with the Internal Revenue Service or IRS can be serious. Penalties for failing to timely file a foreign information return can range from a minimum of $10,000 to several million dollars. The authority to assess most international penalties can be found in Sections 6038 and 6039 of the Internal Revenue Code. Originally, these penalties were assessed manually against taxpayers during an audit. However, beginning January 1, 2009, the IRS began systematically assessing monetary penalties for failing to disclose interests in offshore/foreign assets and holdings on a foreign information return. The IRS treats international penalties as summarily assessable, as they are not subject to deficiency procedures, wherein individuals receive a…