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Tax Returns Tax Penalties Foreign Corporations

BakerHostetler

D.C. Court of Appeals Strengthens IRS’ Ability to Collect Penalties for Not Reporting Foreign Company Ownership

BakerHostetler on

On April 3, 2023, the United States Tax Court issued its opinion in Farhy v. Commissioner of Internal Revenue, which upset long-standing views on how the IRS may assess and collect penalties for failure to file certain tax...more

Holland & Knight LLP

Tax Court: IRS Lacks Authority to Assess Certain Foreign Information Return Penalties

Holland & Knight LLP on

The U.S. Tax Court (USTC) on April 3, 2023, issued its opinion in Alon Farhy v. Commissioner, which held that the IRS lacks authority to assess certain foreign-related information return penalties pursuant to Section...more

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