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International Tax Blog - New and Interesting International Tax Issues

Charts of Examples in Code §6038A Regulations: Form 5472 Reporting Requirements


Form 5472 is used to provide information required under Code §§6038A and 6038C when reportable transactions occur during the tax year of a reporting corporation with a foreign or domestic related party.  The reportable transactions are essentially related party transactions.  Consequently, Form 5472 is an important tool in IRS audits relating to transfer pricing and Code §482.  See IRM §

Treas. Reg. §1.6038A-1(m) provides 7 examples that apply the Form 5472 reporting requirement rules.  We have created situational charts that illustrate the examples.  Images of the charts are shown below and links to PDFs of the charts are also available:

1.6038A-1 Ex 1

1.6038A-1 Ex 2

1.6038A-1 Ex 3

1.6038A-1 Ex 4

1.6038A-1 Ex 5

1.6038A-1 Ex 6

1.6038A-1 Ex 7

Tags: 482 Transfer Pricing, Charts - Situational Charts, Form 5472