Y2J
Tax Tools
Three IRS notices provide relief for taxpayers affected by the October 7, 2023 terrorist attacks in Israel:
Effect: If the original due date (or extended due date) falls between Oct 7, 2023 and Sept 30, 2026, the effective due date for both filing and payment becomes Sept 30, 2026. No penalties or interest accrue until after that date.
Form 1040 — Failure-to-file and failure-to-pay penalty computation
Form 2210 — Estimated tax penalty for individuals
Daily compounding interest at the federal short-term rate + 3%
Common penalties for foreign information returns — for reference only
| Form | Description | Penalty |
|---|---|---|
| Form 5471 | Information Return of U.S. Persons with Respect to Certain Foreign Corporations | $10,000 per form per year. Additional $10,000 for each 30-day period of continued non-compliance after IRS notice, up to a maximum additional penalty of $50,000. |
| Form 5472 | Information Return of a 25% Foreign-Owned U.S. Corporation or Foreign Corporation Engaged in a U.S. Trade or Business | $25,000 per form per year. Additional $25,000 for each 30-day period after IRS notice of continued non-compliance. |
| Form 3520 | Annual Return to Report Transactions with Foreign Trusts and Receipt of Certain Foreign Gifts | Foreign trusts: 35% of gross value of property transferred to a foreign trust; 35% of gross distributions received from a foreign trust; 5% of gross value of trust corpus if information return not filed. Foreign gifts: 5% of gift amount per month (or part), up to 25%. |
| FBAR (FinCEN 114) |
Report of Foreign Bank and Financial Accounts | Non-willful: Up to $16,536 per violation (2025, adjusted annually). Willful: Greater of $165,353 (2025, adjusted annually) or 50% of account balance per violation. |
| Form 8938 (FATCA) |
Statement of Specified Foreign Financial Assets | $10,000 failure-to-file penalty. Additional $10,000 for each 30-day period after IRS notice, up to $60,000. Plus 40% accuracy-related penalty on any underpayment attributable to undisclosed foreign financial assets. |
| Form 8865 | Return of U.S. Persons with Respect to Certain Foreign Partnerships | $10,000 per form per year. Additional $10,000 for each 30-day period of continued non-compliance after IRS notice, up to $50,000. |
| Form 926 | Return by a U.S. Transferor of Property to a Foreign Corporation | 10% of the value of property transferred, up to a maximum of $100,000. |