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IRS LETTER 6311 WARNS ABOUT SECTION 965 COMPLIANCE

Oct 15, 2020

We give a brief overview of IRC Section 965 and the transition tax, discuss the impact of the Letter 6311 warnings, and give our take on how to respond to the IRS.

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FORM 3520 - TOP 6 TRAPS

Aug 24, 2020

The complex nature of reporting on the Form 3520 is in many ways an outgrowth of the somewhat unusual legal form that trusts take as well as the temptation to abuse non-US trusts to avoid or defer US taxes.

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2019 DATA BOOK AND IRS ENFORCEMENT ACTIVITIES

Jul 09, 2020

This past week, the IRS published its annual Data Book, which offers a bird’s-eye view of the IRS’s activities during the past year, with a particular emphasis on enforcement activities, including audits and civil tax penalties.

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