Own A Foreign Corporation? New Case Lets IRS Collect $10K Immediately

A new court case now allows the IRS to immediately collect $10,000 penalties from U.S. owners of foreign corporations who fail to file Form 5471. For taxpayers with foreign corporations, the IRS just strengthened its hand in collecting reporting penalties without going to court. The so-called “Farhy defense” suffered another major blow on February 27, … Continue reading Own A Foreign Corporation? New Case Lets IRS Collect $10K Immediately →

Big Win for Taxpayers with Foreign Assets: IRS Lacks Authority to Assess & Collect Penalties for Failure to File Foreign Information Returns

The Internal Revenue Service (IRS) was sucker-punched by the Tax Court on April 3, 2023 in the case of Farhy v. Commissioner, 160 T.C. No. 6 (2023). In that case, the Tax Court held that the IRS does not have the authority to assess and collect penalties asserted under Internal Revenue Code Section 6038(b), in the … Continue reading Big Win for Taxpayers with Foreign Assets: IRS Lacks Authority to Assess & Collect Penalties for Failure to File Foreign Information Returns →