Filing of Forms

Brian DooleySupportIndividual
Summary: Brian Dooley, a CPA, supports the IRS's consideration of alternatives for filing Form 5472 but emphasizes that the form remains critical for tracking related party transactions. He suggests that extensions for Form 1120 should apply to Form 5472 and recommends making the filing mandatory even when no transactions occur.
Dear Internal Revenue Service, I deeply appreciate your desire to look at alternatives to filing Form 5472. This Form is often overlooked by tax return preparers. Yet, this is one of the most important forms for the Service to track related party transactions. Tracking these transactions is necessary to insure compliance with our tax laws. I believe that separating the filing can be helpful. However, since many tax return preparers are unaware of Form 5472, the extension to file the Form 1120F or Form 1120 should apply to the Form 5472. Further, I believe that the Form 1120F and the Form 1120 should direct the fling of Form 5472 with the word "may" replaced by "must" (for example on Line 7-c of Form 1120). The Form 5472 should be filed even if the taxpayer and/or his preparer believes that reportable transactions do not exist. In accounting and tax planning "zero" is an important as any other number. Each line on the Form 5472 should require a number ("zero" if there is no transaction) I believe the Form 5472 should require signature by the taxpayer and the preparer. Lastly, I am hopping that the IRS "advertise" the Form 5472 as to avoid unfair penalities when it is unintentionally not filed because the preparer is unaware of its existence. Respectively submitted, Brian Dooley, CPA, MBT

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