Form 5471

Form 5471, Penalties, Tax Court

IRS Lacks Statutory Authority to Assess Certain Form 5471 Penalties

By Jason B. Freeman Apr 12, 2023
Controlled Foreign Corporation (CFC), Cross-Border Tax Insights, Form 5471, International Tax, IRS Disclosure, Offshore Tax, Outbound Transfer, Tax Planning

Reviewing a Foreign Legal Structure

By Freeman Law Jan 24, 2023
Cross-Border Tax Insights, Form 5471, International Tax

IRS Private Letter Ruling Allows Foreign Corporation’s Untimely Form 5471 Election

By Jason B. Freeman May 04, 2020