IRS Enforcement Issues in the News
IRS researchers and academic economists have issued a paper concluding that wealthy taxpayers may been failing to report income at a rate higher that previously estimated. The paper mentions offshore…
Our Blog
Controlled Foreign Corporation ("CFC") FATCA Immigration Internal Revenue Code New York Nonresidents OVDI Streamlined Streamlined Procedure Tax Compliance Voluntary disclosure
Whistleblowers and The Global Reach of The IRS and NYS.
Recent headlines and articles in the financial press have been rich with inflammatory buzz words referencing “whistleblower payouts”, “indictments for tax evasion”, “state & local tax enforcement”, renewed threats of…
Entity Classification Foreign Tax Preparation Forms and Filings Internal Revenue Code Internal Revenue Service International Taxation Tax Compliance
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…