Please read this first – https://www.mooresrowland.tax/2019/04/new-form-14457-voluntary-disclosure.html
On April 16th, the IRS identified 3 additional compliance campaigns
One of them is the – Loose Filed Forms 5471
Practice Area: Withholding & International Individual Compliance
Lead Executive: John Cardone, director of Withholding & International Individual Compliance
Form 5471, Information Return of U.S. Persons With Respect to Certain Foreign Corporations, must be attached to an income tax return (or a partnership or exempt organization return, if applicable) and filed by the return’s due date including extensions. Some taxpayers are incorrectly filing Forms 5471 by sending the form to the IRS without attaching it to a tax return (or partnership or exempt organization return, if applicable).
If a Form 5471 is required to be filed and was not attached to an original return, an amended return with the Form 5471 attached should be filed. The goal of this campaign is to improve compliance with the requirement to attach a Form 5471 to an income tax, partnership or exempt organization return.
The campaign does not address whether filing an amended return with the Form 5471 appropriately attached will enable taxpayers to mitigate consequences that might otherwise follow from perceived compliance defects.