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  • New IRS practice unit: “Substantial compliance” doctrine, international information return penalties
    The IRS Large Business and International (LB&I) division last week publicly released a “practice unit” that addresses what the term “substantially complete” means with reference to international information return penalties, particularly Form 5471. The IRS recently released a new International Practice Unit (“IPU”) on failures to file form 5471.  IPUs are meant to act as a
  • U.S. Taxpayers at New Risk of Audit from OVDP Declines and Withdrawals Campaign
    Last year, the US Treasury Inspector General for Tax Administration (TIGTA) released a report which assessed how well that IRS was managing the Offshore Voluntary Disclosure Program (OVDP). OVDP is one of the programs taxpayers may use to become compliant if they previously had failed to report offshore income on their tax returns and file
  • FATCA Noncompliant Accounts may be Frozen or Blocked
    Many of our clients with foreign accounts have received FATCA letters.  The letters seek personal information regarding the account holder in order to comply with the US FATCA law. In recent weeks, government authorities in a few foreign countries have announced that account holders that have received FATCA letters and have not responded with the
  • Complicated Form 5471 filing requirements simplified for dormant foreign corporations
      The reporting requirements for IRS Form 5471 are complex, including ‘category of filer’ and required schedules.  However, very few taxpayers know that there are special simplified filing rules for a foreign dormant corporation. IRS Revenue Procedure 92-70, specifies specific, conditions that must all be met in order for a foreign corporation to be considered


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