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IRS Issues Significant Guidance on Foreign Trusts: Forms 3520 and Form 3520-A

In 3520, International Tax by Matthew RobertsLeave a Comment

In 1996, Congress enacted Section 6048.[1]   Under that provision, certain persons are responsible for reporting transactions or relationships with foreign trusts on IRS Form 3520 and/or IRS Form 3520-A.  The failure to timely file an IRS Form 3520 and/or IRS Form 3520-A can result in significant civil penalties and potential criminal referrals.   However, until recently, there has been significant …

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J5 Continues its Efforts to Identity International Tax Cheats

In Fraud, International Tax, Offshore Tax by Matthew RobertsLeave a Comment

The Joint Chiefs of Global Tax Enforcement (known as the “J5”) has been busy the last few months.  The group – compromised of tax department heads from Australia, England, Canada, the Netherlands, and the United States – was formed in June 2018 to facilitate the sharing of information regarding international tax cheats.  A summary of some of their more recent …