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…
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…
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…
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…
Form 3520 Annual Return to Report Transactions with Foreign Trusts and Receipt of Certain Foreign Gifts and Form 3520-A Annual Information Return of Foreign Trust with a U.S. Owner are…
With an ever expanding global economy and migrating workforce, it comes as no surprise that marriage and divorce transcends borders as well, creating unique tax implications for those involved. Generally,…
A U.S. beneficiary of both a Foreign Grantor Trust and Non-Grantor Trust has certain reporting obligations that they must meet with respect to their interest in a foreign trust. Form…
Just months after the massive document leak known as the Panama Papers, 1.3 million files from the Bahama’s corporate registry has hit the internet in what is being referred to…
