The IRS recently made two important revisions to the filing instructions for Form 5471 (Information Return of U.S. Persons With Respect to Certain Foreign Corporations) for 2012. First, Category 5 filers may now claim the constructive ownership exception, which should reduce the filing burden for a large number of prior Category 5 filers. Second, taxpayers who claim this exception are no longer required to attach the statement described in the instructions for Item D (Person(s) on Whose Behalf This Information Return Is Filed) to their tax returns.

