Monthly update · Published

Form 5472 Tax Filing Update — September 2026

Bottom line: No direct Form 5472 statutory, final-regulation, or final-instruction change was identified in the reviewed primary-source set through September 7, 2026. Related developments can still matter for some foreign-owned businesses.

Published and reviewed 2026-09-07 · Current through 2026-09-07 · By Arik Rozen, CPA

At a glance

Court decision: Safdieh addressed §6038(b) penalties and Form 5471-type reporting, not Form 5472.
Effective law / proposed regulations: IRC §4475 is a separate remittance-transfer excise tax; the April IRS announcement describes proposals, not final rules.
Upcoming deadline: September 15 and October 15 are general extended-return reminders for some calendar-year entities.
No direct Form 5472 change: No direct statutory, final-regulation, or final-instruction change was identified in the reviewed primary-source set through September 7.

Important dates

September 15, 2026 — Extended partnership and S corporation returns. General reminder for certain calendar-year Forms 1065 and 1120-S that received a valid, timely extension.
October 15, 2026 — Certain extended corporate returns. General reminder for certain calendar-year Form 1120-related returns that received a valid, timely extension.

These dates are not universal. Confirm entity classification, tax year, and whether a valid extension was filed before relying on a calendar deadline.

What changed

Safdieh v. Commissioner is related penalty context, not a Form 5472 holding

On February 27, 2026, the Second Circuit decided Safdieh v. Commissioner. The decision concerned IRC §6038(b) penalties, Form 5471-type reporting, and administrative assessment.

It did not directly decide IRC §6038A(d) or Form 5472. Those provisions are distinct. This update does not predict how another court would resolve a different statute or fact pattern.

Safdieh v. Commissioner (Second Circuit opinion mirror) · IRC § 6038 (U.S. House Office of the Law Revision Counsel) · IRC § 6038A (U.S. House Office of the Law Revision Counsel)

Remittance-transfer tax is separate from Form 5472

Public Law 119-21 §70604 added IRC §4475, a separate 1% excise tax on certain remittance transfers funded by cash, money order, cashier’s check, or a similar physical instrument after December 31, 2025. The statute excludes qualifying bank-account, debit-card, and credit-card funded transfers.

The Treasury/IRS announcement of April 10, 2026 describes proposed regulations, not final regulations. This is separate from Form 5472; whether it affects a business depends on the particular transfer and facts.

Public Law 119-21, § 70604 · IRS: proposed remittance-transfer-tax regulations

Deadline reminders

September 15 is a general reminder for certain calendar-year partnership and S corporation returns that received a timely extension. October 15 is a general reminder for certain calendar-year Form 1120-related returns with a timely extension.

These are calendar reminders, not universal deadlines: entity classification, tax year, and a valid timely extension can change the analysis. Form 5472 follows the due date, including extensions, of the related income tax return.

Review the current IRS instructions for Forms 1065, 1120, 5472, and Form 7004 before acting.

What did not change

In this review, we found no direct Form 5472 statutory amendment, final regulation, or final instruction change through September 7, 2026.

That limited conclusion reflects the primary sources listed below; it is not a claim that every possible authority or taxpayer fact pattern was reviewed.

Arik’s practical note: Keep the entity’s classification, related-party transaction records, and income-return extension record together. Those facts matter before drawing a filing or deadline conclusion.

Editorial note: One candidate item was withheld because this primary-source review did not substantiate it.

Primary sources reviewed

Corrections and update policy

We correct material factual errors when primary sources support a correction and note substantive updates on the relevant edition. Send a source-based correction request through our support channel. This editorial update is general information, not individualized tax or legal advice.