Why 25% Foreign-Owned Blocker Corps. Must File Form 5472
Law360 (August 17, 2018, 2:49 PM EDT) -- In transactions between unrelated third parties, the prices charged between the parties are controlled by market forces. However, with transactions between related parties, there is no corresponding conflict of interest between the parties to ensure that market prices are used. The IRS developed Form 5472 to collect information and identify potential tax issues with regard to transactions between a U.S. corporation and related foreign shareholder. The IRS is focused on the prices charged in intercompany transactions to make sure taxable income is not being shifted offshore by using nonmarket prices. The nature and amount of the related party or reportable transactions...
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