The revenue procedure also allows some unrelated minority U.S. shareholders to rely on specified financial statement information to calculate their Subpart F and GILTI inclusions, as well as satisfy reporting requirements with respect to certain CFCs if more detailed tax information is unavailable. It also provides penalty relief to taxpayers in the specified circumstances.
The IRS will amend instructions for Form 5471 to reduce the amount of information that some unrelated minority U.S. shareholders of the CFC are required to provide. It will also limit the filing requirements of U.S. shareholders who only constructively own stock of the CFC solely due to downward attribution from another person.
Jeff Stimpson, IRS grants foreign-stock relief, Accounting today [Internet], October 1, 2019