IRS Disclosure

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
Administrative Procedure Act, Captive Insurance, Economic Substance, IRS Disclosure, IRS Notices

Micro-Captive Insurance Arrangements Disclosure

By Freeman Law Nov 22, 2022
Cross-Border Tax Insights, Form 926, Gain Recognition Agreement, GRA, International Tax, IRS Disclosure, IRS Regulations, Outbound Stock Transfer, Outbound Transfer, Section 367, Section 6038B, Tax Compliance, Tax Planning

Gain Recognition Agreements and Outbound Stock Transfers

By Freeman Law Oct 19, 2022
Form 8275, IRS Disclosure, Penalties

The Art of the Tax Disclosure: How to Avoid Tax Penalties By Disclosing a Return Position

By Jason B. Freeman Aug 04, 2021
IRS Disclosure, Listed transaction, Penalties

Listed Transaction Penalty Upheld by Federal Circuit Court

By Jason B. Freeman Nov 25, 2020