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Do I need to file Form 5472 for my US-incorporated startup as a Canadian citizen?

I founded a startup around two years ago and incorporated in the US because an accelerator program I got into required it. I'm a Canadian citizen. Since we're running on a shoestring budget while bootstrapping, I hired a local accountant to handle our tax filings to keep costs down. The accountant just sent me a draft of our tax returns, and I think there's an error. He's included Form 5472 in the filing. The reason seems to be that I'm a Canadian citizen who owns more than 25% of the company shares, so I meet the ">25% foreign owner" criteria. Here's the issue though - there are absolutely zero transactions between me personally and the business. I'm not taking any salary, and all expenses in the business are standard operational costs completely unrelated to me personally. This is causing me stress because if Form 5472 is actually required, I'm technically late in filing it and could face penalties! When I was initially shopping around for accounting services, someone mentioned this form. I researched it and believed we were exempt based on the Form 5472 "Who Must File" section, specifically exception #1: *there are no reportable transactions between the reporting corporation and the foreign related party*. Am I reading this correctly? I plan to ask my accountant to reconsider, but since I'm working with a smaller local firm rather than a big accounting company, I wanted to get additional opinions. Has anyone dealt with this situation before?

Freya Larsen

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I'm in a similar situation but with a twist - I'm a German citizen with a US corporation, but I do take a small salary. My accountant filed Form 5472 but made a mess of it and now I'm dealing with follow-up questions from the IRS. Has anyone used TurboTax or any other software for this form? My accountant wants to charge me another $1500 to fix the issues he created.

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Omar Hassan

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Most consumer tax software doesn't handle Form 5472 well. I tried using TurboTax for my international business stuff last year and ended up having to hire a specialist anyway. For something this specialized with penalties this high, I'd recommend finding a new accountant who specializes in international tax rather than trying to DIY it.

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Carmen Ortiz

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I went through this exact scenario last year as a Canadian founder with a US-incorporated startup. Your accountant is absolutely correct to include Form 5472. The key issue that many founders miss is that even unpaid work constitutes a "reportable transaction" under current IRS rules. When you're making business decisions, developing strategy, or doing any work for your corporation without compensation, the IRS considers this a service provided by a foreign related party (you) to the US corporation. This triggers the Form 5472 requirement regardless of whether money changes hands. The "no reportable transactions" exception that you found is much narrower than it appears. It really only applies if you're a completely passive investor with zero involvement in business operations. Since you're the founder actively running the company, you definitely have reportable transactions. I'd recommend filing the form as soon as possible. If you're late, you can request penalty abatement based on reasonable cause - the fact that you genuinely misunderstood the requirements and sought professional advice can help your case. The $25,000 penalty is no joke for a bootstrapped startup, but acting quickly and showing good faith effort to comply usually results in reduced or waived penalties. Your accountant may be from a smaller firm, but they're giving you correct advice on this one. Better to file it properly now than face the consequences later.

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Just want to add that the difference in penalties/interest between the CP2000 and CP3219a is normal. The CP2000 calculates projected interest through an estimated payment date. The CP3219a recalculates based on current date. Since you already paid more than what's on the CP3219a, you'll likely get a small refund once everything is sorted out (though it might take months). When I had this issue, they eventually sent me a check for about $47 without me even requesting it.

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Sofia Torres

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Is this why my CP2000 and CP3219a had different amounts too? I thought they made a mistake calculating interest!

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Yes, that's exactly why. The CP2000 includes projected interest through an estimated payment date (usually 30-60 days from the notice date). The CP3219a recalculates based on the actual current date when it's issued. If there's a long gap between notices, or if interest rates changed, the amounts will be different. It's actually a good sign that your CP3219a shows a lower amount - it means if you've already paid the CP2000 amount, you've overpaid and should eventually get the difference back.

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This is such a helpful thread! I'm dealing with a similar situation where I received a CP2000 last month and I'm terrified of making the same mistake. Based on what everyone's shared here, it sounds like the key is making sure you properly fill out the response form AND include payment, not just send a check. Can someone clarify exactly which boxes need to be checked on the CP2000 response form? I see there are options to agree, disagree, or partially agree with the proposed changes. If I agree with everything and want to pay the full amount, do I check "agree" and then also sign and date it? I want to make sure I do this right the first time so I don't end up in the same situation as OP with conflicting notices. Also, should I send the payment and response form together in the same envelope, or separately? The instructions aren't super clear about this.

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Donna Cline

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FYI - it's actually better to have refunds direct deposited to your account instead of having checks sent through preparers. Always use your own bank info, never let them handle your money. Good luck getting this resolved.

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Lesson learned FOR SURE. Never again! Will be doing my own taxes next year.

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Ava Johnson

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This is absolutely infuriating and unfortunately way too common. As someone who works in financial services, I can tell you that what they're doing is 100% illegal. The moment that refund check was issued in your name, it became your property - not theirs to hold hostage. Here's what I'd recommend doing immediately: 1. Send them a written demand (certified mail) stating they have 24 hours to release YOUR check 2. Contact your state's consumer protection agency 3. File a complaint with the IRS Return Preparer Office 4. If they're part of a franchise, escalate to corporate immediately The fact that they suddenly said you could pick it up after mentioning the IRS tells you everything you need to know - they KNOW they're in the wrong. Don't let them get away with this predatory behavior. Document everything and make sure to warn others about this place once you get your money back. You shouldn't have to wait weeks for new SS cards when they already had sufficient documentation to file your return successfully. This is pure intimidation tactics.

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Ok I'm totally confused now. I have a W-2 from my employer AND a W-2 from the insurance company for the same health plan. Do I need to report both? Seems like double counting the same thing??

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StormChaser

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You shouldn't have a W-2 from an insurance company - W-2s only come from employers. What you might have is a 1095-B or 1095-C from the insurance company, which just reports your health coverage for the year but doesn't represent income. If you actually have two W-2s, check the Employer Identification Numbers (EIN) in Box b on both forms. If they're different, they're from different entities and both need to be reported. If they're reporting the same income twice, that's an error that needs to be corrected. Can you check the form numbers and EINs and report back?

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I'm dealing with this exact same situation right now! Got my regular W-2 from my employer plus this separate one for marketplace premiums they paid. Mine shows $3,600 in Box 1 with Social Security and Medicare taxes withheld but no federal income tax. Reading through all these responses has been super helpful - I had no idea this was taxable income until now. My HR department didn't explain any of this when they set up the marketplace coverage for me. I thought they were just being helpful by contributing to my health insurance, but now I realize I'm going to owe taxes on their "help." Has anyone here actually filed their return with both W-2s yet? I'm curious if TurboTax handles this smoothly or if there are any gotchas I should watch out for when entering the marketplace premium W-2. Also wondering if this affects my refund timing since it's technically additional income I wasn't expecting to report. Thanks everyone for sharing your experiences - this thread is way more helpful than the IRS website for understanding this situation!

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Ruby Knight

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For what it's worth, I report everything regardless of the amount. $74 is so small it won't impact your overall tax situation much, but it does give you the opportunity to deduct mileage and other expenses related to that gig work. If you drove more than about 120 miles for those deliveries, you could actually show a loss on your Schedule C (using the standard mileage deduction of $0.625/mile for 2022), which could slightly reduce your overall tax bill.

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So if I understand right, I could potentially deduct my mileage for the deliveries? I'd guess I drove around 60-70 miles total for the few deliveries I did. Would that still be worth claiming?

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Ruby Knight

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Yes, you can deduct your mileage for the deliveries you did. For 60-70 miles, you'd get a deduction of about $37-44 using the standard mileage rate. This would reduce your taxable income from the $74 down to around $30-37. While it's not a huge amount, it's still worth claiming because it shows you're reporting everything properly and you might as well get the deductions you're entitled to. It also establishes a pattern of compliance if you decide to do more gig work in the future.

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Just an FYI - If you plan to do more gig work in the future, it's good practice to start tracking everything properly now, even for small amounts. Get a mileage tracking app, keep receipts for any expenses, and set aside about 25-30% for taxes. That way when you make more than $600 and DO get a 1099, you're already in the habit of doing things correctly.

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Logan Stewart

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What's the best app for tracking mileage? I'm thinking about starting Doordash this summer.

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Aria Khan

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I've been using MileIQ for about a year now and it's been great. It automatically tracks your drives using GPS and lets you swipe to categorize them as business or personal. There's also Stride which is free and specifically designed for gig workers - it tracks mileage, expenses, and even helps estimate quarterly taxes. Both are way better than trying to keep a paper log!

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