No, the MITT is not expected to take the place of Form(s) 5471, 5472, & 8865. The MITT was created to enable quick and efficient risk assessment of related party transactions given the Compliance Assurance Process (CAP)'s time constraints. This purpose is distinct from the roles of Forms 5471, 5472, and 8865, which are more comprehensive in their requirements for reporting information related to foreign corporations, foreign-owned U.S. corporations or foreign corporations engaged in a U.S. trade or business, and U.S. persons with respect to certain foreign partnerships, respectively. The MITT serves as a tool for the IRS to assess risks associated with related party transactions, but it does not replace the detailed reporting and compliance obligations fulfilled by Forms 5471, 5472, and 8865.
Sources:
The Unsimplification of U.S. International Tax Reporting
IRS FAQ
IRS FAQ
IRS FAQ
IRS FAQ
IRS FAQ
IRS FAQ
