Skip to content
Tax Law Center Blog

Tax Law Center Blog

  • Tax & Foreign Assets
    • Tax Law Services
    • Foreign Asset Planning
  • About
  • Contact Us
Close Button

Day: June 29, 2017

New IRS practice unit: “Substantial compliance” doctrine, international information return penalties

29 June, 2017

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

Read More

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
  • Navigating the Step Up in Basis: Core Rules, Critical Exceptions, and Strategic BenefitsMay 7, 2026
  • The Tax Consequences of Cross-Border Trusts: Key Reminders from the IRS April 2026 Comprehensive GuidanceMay 5, 2026
  • Advancing the Exclusion: “Packing and Stacking” Strategies Under IRC § 1202May 1, 2026
  • Navigating Foreign Trust Compliance: Key Takeaways from the IRS April 2026 Foreign Trust Guidance UpdateApril 30, 2026
  • Navigating the IRS First Time Abatement Policy: Mechanics, Eligibility, and ExceptionsMarch 28, 2026

Law Firm Attorney WordPress Theme By Themespride