I understand that the IRS just closed their Delinquent International Informational Procedures in which missing 5471s could be filed without incurring the $10,000 6038B penalty. The IRS is now much more aggressive with the willfulness standard. At this point, I dont see a path in which a CPA assist a client with delinquent foreign Informational return and plan on referring delinquent filers to attorneys. This also seems to substantially increases practice risk for the CPAs in the international area as 5471 complexity has increased exponentially since TCJA.
https://www.accountingtoday.com/opinion ... 5006041727
Any thoughts?