Page 5 - Information Return News Today

The IRS has been busy in the international realm triggering several court decisions that should get the attention of all taxpayers with any level of global reach.

Committee looking at potential park amenities

We continue with Part 2 – International Tax Primer for US Taxpayers and Expatriates with one of the most common forms associated with foreign asset and income reporting to the IRS: Form...

Global minimum tax of 15 per cent will come into effect from next year and by 2025 almost 90 per cent of MNCs having revenues of more 750 million euros will be subject to the levy in every country of operation, said OECD in its report to G20. "The implementation of the global minimum tax is now well underway and will come into effect from the beginning of next year," the Organisation for Economic Cooperation and Development (OECD) said in a report to G20 finance ministers and central b...

On April 3, 2023, the Tax Court in Farhy v. Commissioner rejected IRS efforts to impose penalties on a taxpayer's failure to file Form 5471. According to the Tax Court, these foreign...

US Tax Court issued opinion in Farhy v. Commissioner, holding that the Internal Revenue Service IRS lacked statutory authority to both assess tax penalties under Internal Revenue Code Section 6038b and collect said penalties via a levy against the taxpayer.

The recent Tax Court decision in Farhy demonstrates that clever and novel arguments can carry the day in complex tax litigation matters. In that case, the taxpayer stipulated...

On April 3, 2023, the US Tax Court issued its opinion in Farhy v. Commissioner, holding that the Internal Revenue Service (IRS) lacked the statutory authority to both assess tax...

The recent Tax Court decision is favorable to taxpayers with certain interests in foreign corporations.

The U.S. Tax Court (USTC) on April 3, 2023, issued its opinion in Alon Farhy v. Commissioner, which held that the IRS lacks authority to assess certain foreign-related information...