Rev. proc. 92-70: form 5471 filing procedure for dormant subsidiaries.

• Position: Brief Article

On September 3, 1992, Tax Executives Instituted the following comments with the Internal Revenue Service, commending the IRS for developing Revenue Procedure 92-70, which sets forth a summary filing procedure for filing Form 5471. (TEI's earlier comments on the proposed were reprinted in the November-December 1991 issue of The Tax Executive.) The Institute's comments were prepared under the aegis of its International Tax Committee, whose chair is Lisa Norton of the Ingersoll-Rand Company.

I am writing on behalf of Tax Executives Institute to express our appreciation for the development of Revenue Procedure 92-70 setting forth a summary filing procedure for filing the Form 5471 with respect to dormant foreign corporations.

As you may know, the Institute was asked by the IRS last year to assist in the development of such a procedure. At that time, we wholeheartedly endorsed the idea as providing a "common sense approach to the Form 5471 filing requirement" that would...