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Lippes Mathias LLP

Taxpayer Beware: The Pitfalls of Section 965 Installment Payments

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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

Mayer Brown

Relieved Taxpayers: US Tax Court Reaffirms that IRS Cannot Assess Failure-to-file Penalties

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Every parent remembers when their child learns the meaning of the word “no.” That moment often comes as a shock because, up until that moment, most children are models of obedience and unconditional trust. When children learn...more

BakerHostetler

D.C. Court of Appeals Strengthens IRS’ Ability to Collect Penalties for Not Reporting Foreign Company Ownership

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On April 3, 2023, the United States Tax Court issued its opinion in Farhy v. Commissioner of Internal Revenue, which upset long-standing views on how the IRS may assess and collect penalties for failure to file certain tax...more

Foodman CPAs & Advisors

¿Está Su Preparador De Impuestos De 2023 Haciendo Las Preguntas Correctas?

La temporada de impuestos está aquí y en el 1/2/24, el IRS le recordó a los contribuyentes que elijan cuidadosamente a su preparador de impuestos de 2023 al preparar sus impuestos de 2023. Los contribuyentes son, en última...more

Foodman CPAs & Advisors

Is Your 2023 Tax Preparer Asking You The Right Questions?

Tax season is here and on 2/1/24, the IRS reminded Taxpayers to choose a 2023 Tax Preparer carefully when preparing their 2023 Taxes. Taxpayers are ultimately legally responsible for all the information on their income tax...more

Warner Norcross + Judd

The IRS is Shifting Audit Attention to Large Partnerships and Wealthy Individuals

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In 2009, the IRS created its Global High Wealth Industry Group, known more familiarly as the “Wealth Squad.” This group starts with an examination of a “key case,” which is typically a wealthy person’s individual tax return,...more

Foodman CPAs & Advisors

Understanding Trusts So You Are Not Mislead By The Word “Trust”

Trusts are vehicles that can assist in the preservation of wealth and property for future generations, protect assets, or carry out a charitable purpose. A trust is an entity created and governed under the state law in which...more

Holland & Knight LLP

Tax Court: IRS Lacks Authority to Assess Certain Foreign Information Return Penalties

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The U.S. Tax Court (USTC) on April 3, 2023, issued its opinion in Alon Farhy v. Commissioner, which held that the IRS lacks authority to assess certain foreign-related information return penalties pursuant to Section...more

Dorsey & Whitney LLP

DSU Plans May Run Afoul of U.S. Deferral Election Timing Rules Resulting in Adverse U.S. Tax Treatment

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A Canadian company adopting a deferred share unit plan (DSU plan) for its directors must consider U.S. tax implications for U.S. taxpayers. It is important to remember that U.S. citizens and U.S. residents for tax purposes...more

Sullivan & Worcester

The Most Draconian Tax Rule in the World

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In today's blog, we look at the most draconian tax rule in the world and examine whether the rule is valid. In addition, we examine a recent United States Tax Court case where the court upheld this draconian rule against a UK...more

Freeman Law

The Tax Court in Brief - January 2021

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Freeman Law’s “The Tax Court in Brief” covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose. The Week of January 18 – January 22, 2021 - Adams Challenge (UK)...more

Freeman Law

Everything That You Need To Know About International Tax Penalties

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International information return penalties are civil penalties assessed by the IRS against a United States person for failing to timely file complete and accurate international information returns required by specific...more

Foodman CPAs & Advisors

Are there conflicting signals from IRS as it relates to Section 965?

IRC Section 965 (Treatment of Deferred Foreign Income Upon Transition to Participation Exemption System of Taxation) was part of the TCJA enacted on December 22, 2017.  ...more

Skadden, Arps, Slate, Meagher & Flom LLP

Challenging Tax Cuts and Jobs Act Regulations and IRS Guidance

The Tax Cuts and Jobs Act (TCJA) brought sweeping changes to the U.S. international tax system. Along with those changes came substantial taxpayer uncertainty as to how the TCJA’s rules apply to their unique circumstances....more

Foodman CPAs & Advisors

IRS “BEEFS UP” Section 965 COMPLIANCE For 2017 And 2018 Returns

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On July 2, 2018, the IRS introduced a Compliance Campaign directed at Section 965 (Transition Tax) of the Internal Revenue Code (IRC). In its original launch, the Section 965 Campaign stated that U.S. shareholder are...more

McDermott Will & Schulte

Weekly IRS Roundup September 30 – October 4, 2019

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 30 – October 4, 2019. September 30, 2019: The IRS published a draft of the tax year...more

Foodman CPAs & Advisors

IRS Initiates a Compliance Campaign for U.S. Persons with respect to Certain Foreign Corporations

IRS Form 5471 is used by certain U.S. persons who are officers, directors, or shareholders in certain foreign corporations and must be attached to a covered Taxpayer’s Tax Return.  On April 16, 2019, IRS announced the...more

Clark Hill PLC

IRS Approves Three New Enforcement Campaigns Based on Data Analysis and Employee Feedback

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The IRS has announced three focused enforcement areas, all related to international tax compliance. The three campaigns were identified through data analysis and suggestions from IRS employees, highlighting the IRS’s use of...more

Fenwick & West LLP

The New Foreign Tax Credit Proposed Regulations – An Executive Summary

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Released on November 30, 2018, the foreign tax credit proposed regulations provide a comprehensive new framework for calculating the foreign tax credit in light of several changes made by the Tax Cuts and Jobs Act (TCJA or...more

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