U.S. companies that are 25 percent or more foreign-owned, foreign companies that are engaged in business with the U.S., and certain other multinationals must file a Form 5472 with their corporate U.S. tax return if they engage in a reportable transaction. The form isn't new, but related reporting requirements and penalties have been expanded.
The new US tax reforms represent the largest overhaul to the country’s tax code in more than three decades. They not only significantly lower US corporate tax rates, they change how multinationals are taxed on their non-US operations and their cross-border transactions. Understanding and following with the new rules will create challenges for multinationals. Those that fail to comply will risk financial and reputational damage, and those that fail to take advantage of new benefits will leave money on the table.