Are Form 1120 Schedule M 3 Disclosed 2019-2024

What is IRS 45472? - IRS 45472 is the information return of a 25% foreign-owned US corporation or foreign corporation engaged in a US trade or business. - The form is difficult to file and can have significant consequences if not done correctly. - The IRS has been enforcing this requirement, especially after the tax cuts and Jobs Act of 2017, which made some significant changes to the penalty and the entities required to file Form 5472. - In this video, we will discuss what hasn't changed and the most important changes. - What is the purpose of Form 5472? - The IRS claims that you should use Form 5472 to provide information required under Section 6038A and 6038C about reportable transactions between a reporting corporation and foreign-related parties. - However, this explanation from the IRS can be quite unintelligible, so let's break it down. - The purpose of Form 5472 is to give the IRS insight into whether a US corporation with foreign owners is engaging in shenanigans to manipulate its revenue and expenses and thereby reduce US taxes. - It allows the IRS to examine transactions with foreign corporations or persons that they typically cannot audit. - Do green card holders need to file Form 5472? - No, green card holders or individuals with permanent residence status are not considered foreign persons by the IRS. - Foreign persons, according to the IRS, include non-US citizens, non-US residents, foreign partnerships, associations, companies or corporations not created or organized in the US, foreign estates or trusts, foreign governments or agencies engaged in commercial activity, etc. - What is a reportable transaction? - A reportable transaction is a type of transaction that the IRS considers an indication of possible shenanigans. - Form 5472 is where a foreign-owned US corporation lists all its reportable transactions, unless there are exceptions. - What are the exceptions to filing requirements for...