"It doesn't motivate tp to file form 5471 for last 2 years"

When it comes to F.5471, there're no carrots, just sticks.  Penalties (or the avoidance of which) are the motivation.  You think $10,000 per failure is bad?  It gets worse (see §6038 and its regs)...

• If your client doesn't file, the statute of limitations for assessing tax on the income tax return to which the F.5471 is related will be extended to 3 years after a complete F.5471 is filed unless reasonable cause can be established, in which case, the extension applies only to the items related.
• Your client may have other penalty and interest exposure on Subpart F income, Transition Tax, and GILTI.
• FTC may also be reduced.
• In addition to civil penalties, your client may also be exposed to criminal penalties if the failure is willful (in the event your client chooses not to file in spite of the filing obligation having been determined - and you are required under Circular 230 to advise him of that obligation and the penalty provisions).

FTA is generally not applicable to waiver of penalties with respect to F.5471 unless it's associated with an 1120.  To request abatement based on reasonable cause, your client will need to attach a written statement under penalties of perjury with all the facts laid out for the consideration of the district director or the director of the service center.  My understanding is that this is not an easy sell.