miss form 5471 for two tax years 2019-2020

[skyworks]

Hi,

I have a client, the form 5471 were properly filed before 2019, but was missed on 2019 and 2020 returns.

Now 2021 is on extension, any suggestion on how to fix the missed two years? The foreign companies they own did not  have much net profit.

Thanks!

[sjrcpa · Accepted solution]

Amend the 2019 and 2020 returns to include the 5471.

Prepare client for the ginormous penalty notices.

[skyworks]

Anyone had experience with IRS apply penalty relief for form 5471?

Or First-time penalty abatement?

Thanks!

[sjrcpa]

Include the reasonable cause explanation with the amended returns.

It better be really good. In my past experience death or serious illness of responsible person counts. Not much else does.

I don't know if it's eligible for first time abatement.