2016-06-07
Today we published a flowchart on our sister website, Tax-Charts.com, regarding Form 5472 filing requirements. We now have 14 free flowcharts at Tax-Charts.com.
Form 5472 is used to provide information required under Code §§6038A and 6038C when reportable transactions occur during the tax year of a reporting corporation with a foreign or domestic related party. A reporting corporation is either a U.S. corporation that is 25% foreign owned or a foreign corporation that is engaged in a U.S. trade or business. The reportable transactions are essentially related party transactions. Consequently, Form 5472 is an important tool in IRS audits relating to transfer pricing and Code §482. See IRM §4.61.3.4.1.