International tax

Foreign corporations (Form 5471)

Form 5471 reporting for US shareholders, officers, and directors of foreign companies — including filing categories, schedules, and catch-up procedures.

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What we handle

Full Form 5471 compliance for US persons with ownership in foreign corporations — from initial assessment to ongoing annual filings.

Form 5471 preparation (all categories)
Filing category determination (1–5)
Required schedules (E, J, M, P, Q, R, etc.)
Controlled Foreign Corporation (CFC) reporting
GILTI & Subpart F income inclusions
Dormant corporation simplified filing
Streamlined Procedures for delinquent filings

When you need to file

Form 5471 has five filing categories. Most US persons connected to a foreign corporation fall into one of these four common situations.

Category 2

Officer or director

A US citizen or resident is an officer or director of a foreign corporation in which any US person acquired 10% or more ownership (or an additional 10% block) during the year.

Category 3

Acquired 10%+

A US person who acquired stock pushing ownership to 10% or more, became a US person while already owning 10%+, or disposed of stock dropping below 10% during the year.

Category 4

Control of foreign corp

A US person controlled a foreign corporation (more than 50% of voting power or value — direct, indirect, or constructive ownership) at any time during the year.

Category 5

CFC shareholder

A US shareholder (10%+ voting power or value) of a Controlled Foreign Corporation — one where US shareholders collectively own more than 50%.

These are simplified summaries. Actual filing requirements depend on direct, indirect, and constructive ownership rules. Category 1 (section 965 specified foreign corporations) is not shown above. Contact us for a category determination specific to your situation.

Eligibility for the IRS Streamlined Filing Compliance Procedures requires certification of non-willful conduct under penalty of perjury. We assess fit on a case-by-case basis before recommending this path.

Not sure if you need to file?

A short consultation can help us determine your filing category, identify required schedules, and assess any catch-up procedures you may need.

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