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 ...

In the federal income tax world, there are effectively two functions within the Internal Revenue Service (“IRS”). First, the IRS examines tax years and tax returns to determine whether the taxpayer ...

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 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 ...

Interests in or transactions with foreign trusts can cause headaches for federal income tax purposes. Depending on the interest or transactions at issue, U.S. citizens or residents may have to file a ...

The IRS has an interest in U.S. taxpayer transactions overseas. Therefore, it is no surprise that Congress has enacted numerous federal tax reporting laws that require individuals to prepare and file ...