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 ...

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 ...