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Wednesday, August 4, 2021 On July 28, 2021, the IRS secured two victories in court. The first win allows the IRS to impose an additional 35% penalty on an individual as the sole owner and beneficiary of a foreign trust and the second court victory paves the way for the IRS to issue John Doe summonses in connection with its investigation of taxpayers who used an offshore service provider in Panama. A. The Second Circuit held that the IRS can impose a $3,221,183 penalty on an individual in his capacity as both the sole owner and beneficiary of a foreign trust The Second Circuit vacated a district court decision and held that an individual who is both the sole owner and beneficiary of a foreign trust may be subject to a 35% penalty, as the beneficiary receiving distributions from the trust in connection with the failure to file Form 3520 reporting the distributions.

United statesNew yorkJoseph wilsonJohn doeDepartment of justiceUnion financial services incMoneygram payment systems incPanama offshore legal servicesSecond circuitInternal revenue codeCode sectionCode sectionsSouthern districtMoneygram payment systemsWestern union financial servicesஒன்றுபட்டது மாநிலங்களில்