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…
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…
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…
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…
Resident aliens working for foreign consulates located within the United States may wonder how much, if any, of their income is subject to U.S. taxation. The first place to look…
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…
