IRC Section 6038(b)

IRC Section 6038(b) imposes an automatic $10,000 penalty for each annual accounting period a U.S. person fails to file Form 5471 for a Controlled Foreign Corporation, plus an additional $10,000 per 30-day period (capped at $50,000) after IRS notification. The statute of limitations on the entire tax return never begins under IRC 6501(c)(8) until the