Forms 5471 and 5472: Meeting the Substantially Complete Standards

Recording of a 110-minute CPE webinar with Q&A

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Conducted on Thursday, January 27, 2022

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Course Materials

This course will discuss best practices for meeting the substantially complete standard for international reporting required for Forms 5471 and 5472 and as applied to other required foreign information returns.


Forms 5471 and 5472 are two of the most complex foreign information reporting forms completed by tax practitioners. Whether by oversight or newly acquired information, these forms are often incomplete or incorrect when submitted. Errors may include the omission of a country or transaction on Form 5472; the category may be omitted on page one, or a taxpayer may use an accounting method other than GAAP used on Form 5471.

Since the criteria for substantial compliance is a facts and circumstances determination, any number of problems could deem a foreign information return not substantially complete and not meeting the information reporting requirements of Sections 6038 or 6038A. The penalties for not meeting these reporting requirements are steep--$10,000 per month to a maximum of $50,000 if not resolved timely.

The penalty abatement process for these filings is challenging. Tax practitioners working with international clients need to understand the threshold for substantial compliance for these cumbersome international reporting forms.

Listen as our panel of foreign tax experts explains current information on meeting the substantial compliance requirements for foreign international reporting.



  1. Substantially complete: background
  2. Foreign international reporting
    1. Form 5471
    2. Form 5472
    3. Other international reporting forms
  3. Penalties
  4. Relevant guidance
  5. Best practices


The panel will review these and other critical issues:

  • What foreign reporting deficiencies are considered substantially incomplete?
  • What forms, in addition to Forms 5471 and 5472, are subject to substantial compliance requirements?
  • What are the best steps to take toward penalty abatement for incomplete submissions?
  • How are omission oversights best handled or corrected?


Kundra, Chaya
Chaya Kundra

Kundra & Associates

Ms. Kundra is a tax law adviser, litigator, and tax controversy attorney who operate practices in Maryland and...  |  Read More

Samtoy, John
John Samtoy

Tax Partner
Holthouse Carlin & Van Trigt

Mr. Samtoy’s practice specializes in international tax compliance and consulting services, with a focus on...  |  Read More

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