This three-part series takes a detailed look at civil penalties, particularly with respect to international information return Form 5471. The statutory framework for civil penalties was discussed in Part One. We now focus on one specific penalty involving failure to...
Introduction This three-part series will focus on IRS civil penalties, mainly as these relate to failure to file international information returns. The framework for civil penalties is discussed first. The focus will then turn to how the framework relates to failure...
With the shutdown entering its fifth week, the U.S. tax industry awaits information relating to recent tax law changes. Concurrently, key events draw closer: the annual IRS efile shutdown, and the commencement of 2026 tax season. Industry awaiting HR1 guidance that is...
The U.S. government shutdown is now into its 16th day, creating confusion and havoc in the U.S. tax community across the globe. The AICPA commented earlier today that fears are growing for the accumulating effects of the shutdown. Last week the AICPA made its second...
Introduction and scope Part One of this article addressed the N.Z. tax implications of distributions from foreign inter vivos trusts[1] as set out in IS 25/18: Income Tax – Whether money or property received by New Zealand tax residents from overseas is income from a...
