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 →

Another Breaking! Farhy Overruled – A Big Loss for Overseas Americans

I have written earlier on the case of Farhy v. Commissioner. There 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 Farhy case, the assessed penalties were imposed for failure to file Form 5471, the IRS form required … Continue reading Another Breaking! Farhy Overruled – A Big Loss for Overseas Americans →

Taxpayer Wins Again on 5471 Penalty – IRS Cannot Assess

In a holding by the US Tax Court on April 8, 2024, the case of Raju J. Mukhi v. Commissioner of Internal Revenue brought into sharp focus the principle of stare decisis and its implications for tax law. The Tax Court rejected the IRS’ assessment of penalties under Section 6038(b), for failure to file Form … Continue reading Taxpayer Wins Again on 5471 Penalty – IRS Cannot Assess →

Is IRS Finally Seeing the Light on Foreign Information Returns?

Bloomberg Tax - I invite readers to enjoy my recently published article, copied in full below. Reproduced with permission. Published December 3, 2021. The Bureau of National Affairs, Inc. (800-372-1033) http://www.bloombergindustry.com published in Tax Insights and Commentary News, online here. Various options are available to correct the problem of missing information returns for U.S. … Continue reading Is IRS Finally Seeing the Light on Foreign Information Returns? →