Panama Papers Bring First Indictments in the U.S.
On December 4, 2018, United States Federal prosecutors indicted four men in connection to the “Panama Papers” data breach first revealed in 2016. The four men were charged with tax…
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New Form 5472 Reporting Requirements
Form 5472 Information Return of a 25% Foreign-Owned U.S. Corporation or a Foreign Corporation Engaged in a U.S. Trade or Business is often an overlooked form. In general, this form…
Controlled Foreign Corporation ("CFC") Foreign Tax Preparation Forms and Filings Internal Revenue Code Internal Revenue Service Tax Compliance
Dormant Foreign Corporations
A Controlled Foreign Corporation (“CFC”) is, in general, a foreign corporation controlled by a U.S. person(s) through ownership of stock. A U.S. person owning at least 10% of a CFC has a…
Forms and Filings Internal Revenue Code Internal Revenue Service International Taxation Tax Compliance
Forms 5471 and 5472 – Meaning of Substantially Complete
The IRS recently released a new International Practice Unit (“IPU”) on failures to file form 5471. IPUs are meant to act as a guide for IRS examiners and give insight…
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UBS to Share Client Information with France
In recent years, Switzerland’s strict bank secrecy laws have made assets in the country a target of investigation for tax authorities around the world. This week, the Swiss Federal Tax…
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Whistleblowers and § 6103(n)
On December 20, 2006, the Tax Relief and Health Care Act (the “Act”) was enacted. The Act amended Internal Revenue Code § 7632 and established a Whistleblower Office in the…