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Circuit Court Reverses Taxpayer-Friendly Decision on Form 5471 Penalties

May 20, 2024

In this week’s blog, we review the D.C. Circuits Court’s reversal of the Farhy decision, a surprising case from last year holding that the IRS lacks the statutory authority to assess certain international return penalties.

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CASE REVIEW – COURT CONSIDERS IF TREATY NONRESIDENT HAS FBAR REQUIREMENT

Mar 20, 2024

The U.S. District Court for the Southern District of California tackled the issue of whether a taxpayer is required to file an FBAR if he has the status of a non-US tax resident by virtue of the tie-breaker provisions of a tax treaty.

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CASE REVIEW – COURT CONSIDERS IF FOREIGN TAX CREDITS CAN REDUCE THE NIIT

Dec 28, 2023

In this week’s blog, we review a recent intriguing decision, in which the U.S. Court of Federal Claims tackled the issue of whether a tax treaty can be used to allow a foreign tax credit to offset the net investment income tax.

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Circuit Court Reverses Taxpayer-Friendly Decision on Form 5471 Penalties

CASE REVIEW – COURT CONSIDERS IF TREATY NONRESIDENT HAS FBAR REQUIREMENT

CASE REVIEW – COURT CONSIDERS IF FOREIGN TAX CREDITS CAN REDUCE THE NIIT

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