environment and climate | January 19, 2026

What is considered a reportable transaction?

A reportable transaction is a transaction described in one or more of the following categories. Listed Transactions. A listed transaction is a transaction that is the same as or substantially similar to one of the types of transactions that the IRS has determined to be a tax avoidance transaction.

What is the purpose of form 8621?

Tax form 8621, Information Return by a Shareholder of a Passive Foreign Investment Company or Qualified Electing Fund, is used to report income from foreign mutual funds, also referred to as passive foreign investment companies (PFICs).

A “Reportable Transaction” is generally a transaction of a type that the IRS has determined as having a potential for tax avoidance or evasion. The IRS provides penalties of up to $250,000 per transaction for failure to report activity in any of these types of transactions.

What is a reportable transaction for tax purposes?

A reportable transaction is a transaction described in one or more of the following categories. A listed transaction is a transaction that is the same as or substantially similar to one of the types of transactions that the IRS has determined to be a tax avoidance transaction.

What is a reportable transaction Form 8886?

When a taxpayer participates in certain transactions in which the IRS has deemed the type of transaction prone to illegal tax avoidance — it is is referred to as a Reportable Transaction — and The taxpayer may have to file a form 8886 to report the transaction.

What is a reportable transaction on Form 5472?

A reportable transaction is listed on Form 5472 in Part IV and is a monetary transaction (paid or received) between the foreign party and reporting corporation during that tax year.

Do you need to file a separate Form 5472?

Yes No A separate Form 5472 is required with respect to each related party with which the reporting corporation had a reportable transaction. Only reportable transactions with foreign related parties need to be detailed in Parts IV and V of Form 5472.

What is the reference ID number for Form 5472?

A reference ID number is a number established by or on behalf of the reporting corporation identified in Part I that is assigned to 25% foreign shareholders and/or related foreign parties with respect to which Form 5472 reporting is required.

What is the penalty for failure to file Form 5472?

Penalties for failure to file Form 5472. A penalty of $25,000 will be assessed on any reporting corporation that fails to file Form 5472 when due and in the manner prescribed. The penalty also applies for failure to maintain records as required by Regulations section 1.6038A-3.