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Offshore Funds › Internal Revenue Service › Taxable Income

Allen Barron, Inc.

How Does the IRS Define Willfulness in Unreported or Under-reported Offshore Income

Allen Barron, Inc. on

How does the IRS define willfulness in unreported or under-reported offshore income?  What actions help determine whether a U.S. taxpayer's actions amount to "willful or non-willful" conduct?  Why should U.S. taxpayers be...more

Fox Rothschild LLP

Tax Court’s Decision on YA Global Investments Has Implications for Offshore Entities

Fox Rothschild LLP on

The Tax Court’s decision in YA Global Investments LP v. Commissioner in November sends a warning to the offshore banking, finance and equity investment industries: an offshore entity is engaged in U.S. trade or business when...more

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