International Taxation

A Logical Program Made Unnecessarily Complicated: The IRS’ Approach to International Information Returns
Listen I wish to graciously acknowledge the work of Phillip J. Colasanto, Esq. from the law firm of Agostino & Associates, P.C. whose keen insight and innovative thinking as reflected in his article entitled, “The International Information Reporting Penalties: Is the IRS’s Failure to Embrace a One-Stop Shopping Paradigm Inefficient and Statutorily Deficient?,” has proven invaluable. His …
A Quick Primer on Form 5471 and Some Hidden Pitfalls to Avoid
Listen Form 5471 is triggered in situations where a “U.S. Person” owns an interest in a “foreign” (non-U.S.) corporation. The specific reporting requirements for Form 5471 are found in Internal Revenue Code Sections 6038 and 6046. Broadly speaking, the purpose of Form 5471 is to identify “U.S. Persons” who: own at least 10% of a …
OVDP Sunsetting on September 28 – New Procedures On The Horizon
Listen On September 4, 2018, the Internal Revenue Service (IRS) reminded taxpayers that they have until September 28, 2018 to apply for the Offshore Voluntary Disclosure Program (OVDP). Back in March, the IRS announced that it would be discontinuing the program on September 28, 2018. This does not mean that the IRS is going to discontinue pursuing …