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SUPREME COURT RULES ON CONSTITUTIONALITY OF TRANSITION TAX

Aug 26, 2024

In this week’s blog, we discuss a recent Supreme Court decision upholding the constitutionality of the Section 965 transition tax, as well as the impact the decision could have on current filers, particularly those catching up using the Streamlined Procedures.

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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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SUPREME COURT RULES ON CONSTITUTIONALITY OF TRANSITION TAX

Circuit Court Reverses Taxpayer-Friendly Decision on Form 5471 Penalties

CASE REVIEW – COURT CONSIDERS IF TREATY NONRESIDENT HAS FBAR REQUIREMENT

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