IRS Form 5472

IRS Form 5471 – Information Return of U.S. Persons With Respect to Certain Foreign Corporations

International Reporting Penalties

Where Is the Limit on Penalties for Willful FBAR Violations?

The Recent FBAR Case Allows Multiple Penalties for Single Failure to File FBAR

International Tax Enforcement: The Joint Chiefs of Global Tax Enforcement

Advising International Business Ventures: “Tested Income” under GILTI

U.S. Shareholder: Changes Under the TCJA

Advising International Business Ventures: Tax Reform’s Section 245A Participation Exemption Regime

Second Installment: Advising International Business Ventures: Tax Reform’s “Transition” Tax

Advising International Business Ventures: Tax Reform’s “Transition” Tax

Advising International Business Ventures: Tax Reform’s New GILTI Tax

Advising International Business Ventures: Passive Foreign Investment Companies (PFICs)

Advising International Business Ventures: Controlled Foreign Corporations and Subpart F

Advising International Business Ventures: Tax Reform and a Quasi-Territorial Tax System

International Tax Enforcement: The Joint Chiefs of Global Tax Enforcement

FBAR Penalty Update

New Changes Are Coming to Partnership Withholding