On April 16, 2019, the Large Business and International (LB&I) Division of the Internal Revenue Service (IRS) announced three new compliance campaigns. The campaigns focus on: Transfer pricing for ...

Forbes contributors publish independent expert analyses and insights. Matthew Roberts is a tax attorney who covers tax litigation and fraud. Taxpayers with foreign assets often have international ...

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 ...

In the recent U.S. Tax Court’s decision in Farhy v. Commissioner 160 T.C, No. 6 (April 3, 2023), the court ruled that the Internal Revenue Service lacks authority to assess and collect penalties from ...

The American Institute of CPAs is asking the Internal Revenue Service to provide relief from tax penalties to taxpayers who are required for the first time to file information returns related to ...

Globalization has created extraordinary opportunities for U.S. taxpayers and multinational businesses. Yet, it has also placed U.S. accountants at the center of a fast-moving regulatory environment.

The recent Tax Court decision in Farhy demonstrates that clever and novel arguments can carry the day in complex tax litigation matters. In that case, the taxpayer stipulated that he: (1) had Form ...