US citizen who resides abroad and who is a shareholder in a foreign corporation must file Form 5471.
US person who is officer, director or shareholder in a certain foreign corporation must file form 5471. Any US person who fails to file the form is subject to $10,000 penalty. If the failure continues for more than 90 days after the date the IRS mails notice of failure, the additional penalty is limited to $50,000.
U.S. Person is defined as....
· a citizen or resident of the United States;
· a domestic partnership;
· a domestic corporation;
· an estate or trust that is not a foreign estate or trust.
