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Internal Revenue Service › Penalties › Foreign Corporations

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
Lippes Mathias LLP

Taxpayer Beware: The Pitfalls of Section 965 Installment Payments

Lippes Mathias LLP on

For the taxable years ending on December 31, 2017, and 2018, Section 965[1] of the Internal Revenue Code required U.S. shareholders (as defined in Section 951(b)) to pay a transition tax on the untaxed foreign earnings of...more

Fox Rothschild LLP

Tax Court Rules IRS Cannot Assess Certain International Reporting Penalties

Fox Rothschild LLP on

In a monumental opinion, the Tax Court recently held that the IRS lacks authority to assess penalties imposed by IRC § 6038(b)(1) or (2). In Fahry v. Commissioner, the taxpayer failed to file Forms 5471 reporting his interest...more

Fuerst Ittleman David & Joseph

FinCEN Issues Final Rule for Beneficial Ownership Reporting Requirements Under the Corporate Transparency Act

Fuerst Ittleman David & Joseph on

On September 29, 2022, the Financial Crimes Enforcement Network (“FinCEN”) promulgated its much-anticipated Final Rule implementing the beneficial ownership reporting scheme mandated by the Corporate Transparency Act....more

Farrell Fritz, P.C.

Reporting A Closely Held U.S. Corporation’s Overseas Activities

Farrell Fritz, P.C. on

We have heard a lot about large, publicly-traded U.S. corporations that have parked trillions of dollars overseas to avoid the payment of U.S. income tax. We have heard how the tax system must be seriously broken to have so...more

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