U.S. persons who invest in foreign activities often have U.S. reporting obligations. A common international reporting requirement for many U.S. persons is IRS Form 5471, Information Return of U.S.
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 ...
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 ...
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