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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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CORPORATE RESTRUCTURING – A TRAP FOR THE UNWARY EXPAT

Feb 28, 2024

In this week’s blog, we focus on corporate restructurings, which are ripe for misunderstanding and complacency, given that the foreign company rules in the US and in your country of residence can be significantly at odds.

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THE ONEROUS TAXATION OF PFIC DISTRIBUTIONS

Aug 10, 2023

In this blog, we dive into the PFIC tax itself, and explain how it functions as a powerful anti-deferral tool for the IRS.

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Circuit Court Reverses Taxpayer-Friendly Decision on Form 5471 Penalties

CORPORATE RESTRUCTURING – A TRAP FOR THE UNWARY EXPAT

THE ONEROUS TAXATION OF PFIC DISTRIBUTIONS

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