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Robert Goulder considers whether a taxpayer-friendly outcome in Farhy would spark a general reformation of the IRS international information reporting penalties.
U.S. parented corporations that have foreign operations conducted through a foreign legal structure have significant U.S. tax filing and reporting obligations.
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.
When dealing with individuals for US tax, one of the key important factors in determining whether that person qualifies as a resident of the United…