The U.S. IRS has released an international practice unit: Failure to File the Form 5471 – Category 2 and 3 Filers – Monetary Penalty. Form 5471 is an information return of U.S. persons with respect to certain foreign corporations under IRC 6046(a) and is filed by attaching it to an individual income tax return, a partnership return, a corporation return, an estate return, or a trust return. The practice unit covers the process for determining whether the filing requirement applies, and if it…