On 10/24/24, the National Taxpayer Advocate shared on its NTA Blog that the IRS has discontinued its policy of automatically imposing penalties for late submissions of Form 3520, which pertains to ...
The IRS has recently notified the AICPA’s Foreign Trust Task Force that the IRS plans over the next few months to send out letters to taxpayers who filed Form 3520, Annual Return to Report ...
United States citizens and residents are often not aware of the myriad of foreign information return filing obligations that exist under federal tax laws. For example, buried within the Code are ...
The IRS continues to aggressively enforce certain foreign information return obligations. In many cases, these enforcement efforts are automatic—that is, the agency simply imposes the applicable ...
The American Institute of CPAs sent comment letters to the Internal Revenue Service requesting changes in two forms used to report on foreign trusts, along with more guidance on energy tax credits and ...
On May 8, the IRS issued proposed regulations addressing matters related to foreign trusts and large gifts received from "nonresident aliens" (NRAs) by a U.S. person. See REG-124850-08 (proposed ...
In Estate of Joseph A. Wilson v. United States of America, an estate brought an action for the return of $3,221,183, which it paid to the Internal Revenue Service as a penalty for a late filing of ...
The Internal Revenue Service has published 2010 statistics on foreign trusts indicating an increasing interest in foreign investment by U.S. taxpayers, and the impact of changes made in 1996 to ...