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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...
U.S. parented corporations that have foreign operations conducted through a foreign legal structure have significant U.S. tax filing and reporting obligations.
The Internal Revenue Service has been steadily ramping up its enforcement of partnership tax compliance.
This year the extended tax filing deadline for U.S. citizens or residents, sole proprietorships, C corporations, and single-owner LLCs is Monday, October 17, 2022. Through the course of...
The 2022 Global Penalty Relief | Notice 2022-36 | Who qualifies and who does not? Relevant Implications for taxpayers with international assets/accounts. The IRS has...