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Day: June 28, 2015

Penalties for Form 5472 Information Return of a 25% Foreign-Owned U.S. Corporation or a Foreign Corporation Engaged in a U.S. Trade or Business

28 June, 2015

We would like to highlight a recent change in the IRS’ policy with respect assessing statutory late filing penalties related to certain international information forms. Of particular concern to international businesses is the revised policy

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Vatican Signs FATCA Agreement

28 June, 2015

Praying may not be enough for non-compliant taxpayers (or evaders) under the Foreign Account Tax Compliance Act (FATCA).  The Vatican has become the latest FATCA signatory to share bank information with the US. The Vatican

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Recent Posts

  • New Penalty Landscape: Analyzing the October 2025 Updates to IRM 21.8.2.19.2 for Late-Filed Forms 3520May 27, 2026
  • Late Disclosure of Foreign Gift for Wedding Results in PenaltyMay 15, 2026
  • Kwong: Preserving Client Claims for COVID-Era Penalty and Interest RefundsMay 13, 2026
  • Internal Revenue Service’s Clarification on Reasonable Cause for Form 5472 PenaltiesMay 12, 2026
  • Defending the Cross-Border Client: Join Parag at the NJSEA Annual Conference This JuneMay 9, 2026

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  • About Patel Law Offices
  • Delinquent FinCen Form 114 (FBAR) Filings
  • Delinquent or unfiled IRS Form 5471

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