In December, the IRS posted to its Web site guidance encouraging taxpayers to submit delinquent Forms 5471, Information Return of U.S. Persons With Respect to Certain Foreign Corporations, before Jan.

The U.S. Tax Court ruled recently that the U.S. Internal Revenue Service has no statutory authority to assess (or collect) civil penalties under IRC §6038(b) for failure to file or filing late IRS ...

Notice 2018-13 details the government’s intent to issue regulations addressing additional Section 965 computational issues. The new regulations will clarify, among other things, that US shareholders ...

A stock photo of a Red Audit stamp on a 1040 US individual income tax return. Photographed at 50mp with the Canon EOS 5DSR and the 100mm 2.8 L lens. If you fail to file a required Form 5471, your ...

In the recent U.S. Tax Court’s decision in Farhy v. Commissioner 160 T.C, No. 6 (April 3, 2023), the court ruled that the Internal Revenue Service lacks authority to assess and collect penalties from ...