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.

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 ...

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 ...