Our International Tax Group parses a recent federal appellate court ruling in the ongoing battle between the IRS and taxpayers over the maximum penalty for willfully failing to file an FBAR to report offshore accounts as...more
Every U.S. person who has a financial interest in, or signature authority over, any foreign financial accounts (including bank accounts, securities, or other types of financial accounts located outside of the U.S.) must file...more
In late September, the IRS issued final regulations describing six requirements for a transaction or series of transactions to qualify as a reorganization under Section 368(a)(1)(F) (an “F reorganization”). The IRS...more