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Tag Archive for penalty

Offshore Asset And Income Amnesty Mooted By Australia’s Tax Commissioner

Nassim Kadem reports in today’s Australian Financial Review that recently appointed Commissioner Chris Jordan has mooted a new amnesty for disclosure of hidden offshore assets and income. A Tax Office official has confirmed the proposal and apparently, Treasurer Joe Hockey has indicated support for the idea.

The amnesty would cap the retrospective tax and penalty period to four years, making it relatively attractive for Australian taxpayers wanting to come clean and avoid later criminal prosecution and unlimited back taxes. It would be particularly attractive to second and third generation members of wealthy families who have “inherited” the problem of secret offshore caches. Read more

IRS Expands Automated $10,000 Penalty Program to Form 5472

TaxConnections Picture - Money MagnetThe IRS has begun applying automatic penalties to late-filed Form 5472’s. We knew that since 2009 the IRS has automatically assessed a $10,000 penalty for late-filed Forms 5471’s – Information Return of US Persons With Respect to Certain Foreign Corporations.

However, we have been receiving a lot of calls from businesses who have recently received penalty notices regarding late filed or non-filed Form 5472’s.Upon further investigation, we discovered that the IRS has updated its IRM 20.1.9, Penalty Handbook, International Penaltieson March 21, 2013 to now include and Automatic Assessment of this $10,000 Penalty for Form 5472, Information Return of a 25% Foreign-Owned U.S. Corporation or a Foreign Corporation Engaged in a U.S. Trade or Business.

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 (Under Sections 6038A and 6038C of the Internal Revenue Code), is filed as an attachment to the U.S. income tax return by the due date of that return, including extensions. If the reporting corporation’s income tax return is not timely filed, Form 5472 nonetheless must be timely filed at the campus where the return is due. When the income tax return is ultimately filed, a copy of Form 5472 must be attached.The IRM 20.1.9, Penalty Handbook, International Penalties also provides: Read more

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