“The amendments made by subsection (a) [enacting this section and amending section 902 of this title] shall apply to taxable years of domestic corporations beginning after December 31, 1960, with respect to information relating to a foreign corporation or a foreign subsidiary described in section 6038(a) of the Internal Revenue Code of 1986 ...

This form is primarily used by organizations that file Form 990-PF to report information related to tax liabilities for certain activities, including failure to distribute a minimum amount for charitable purposes, excess executive com-pensation, investing in a manner that jeopardizes exempt purposes, and engaging in certain lobbying and politica...

Paragraph (1) shall not apply to any failure if the United States person shows such failure is due to reasonable cause and not to willful neglect. The penalty under paragraph (1) with respect to any exchange shall not exceed $100,000 unless the failure with respect to such exchange was due to intentional disregard. (Added Pub. L. 98–369, div.

Under the regulations, specified individuals (U.S. citizens, residents and certain non-resident aliens) are required to complete and attach Form 8938, Statement of Specified Foreign Financial Assets, to their income tax returns.

Internal Revenue Code Section 6038 is primarily used to disclose foreign assets, corporations and partnerships. The key portions of the IRC 6038 et seq. are as follows:

2021年7月1日 · Sec. 6038 requires every U.S. person to furnish, for any foreign business entity that person controls, the information listed in Sec. 6038(a)(1). The information is reported on Form 5471 or Form 8865, as applicable. Sec. 6038A requires any domestic corporation that is 25% foreign-owned to furnish the information listed in Sec. 6038A(b)(1).

IRC Section 6038 (a) requires information reporting with respect to certain foreign corporations (Form 5471) and describes the information required to be reported on this form.

§6038. Information reporting with respect to cer-tain foreign corporations and partnerships (a) Requirement (1) In general Every United States person shall furnish, with respect to any foreign business entity which such person controls, such information as the Secretary may prescribe relating to— (A) the name, the principal place of busi-

In general, section 6038 refers to information reporting with respect to certain foreign corporations and partnerships. Generally, this requires the reporting of form 5471 to disclose an interest or ownership in a foreign corporation.

Every U.S. person shall make a separate annual information return with respect to each annual accounting period (described in paragraph (e) of this section) of each foreign corporation which that person controls (as defined in paragraph (b) of this section) at any time during such annual accounting period.