The IRS has been closely examining the accurate and timely reporting of foreign gifts and distributions to and from foreign trusts. As part of this effort, the Large Business and International ...

As our previous firm Insights discuss, there is a numbered notice for almost any communication the IRS provides to a taxpayer. See, e.g., CP518 and CP504. In some cases, the taxpayer may safely review ...

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 ...

Forbes contributors publish independent expert analyses and insights. Admitted NY Bar and US Tax Court, covers US international tax law.

In the recent case of Rost v. United States, the Fifth Circuit analyzed whether a foreign entity should be classified as a foreign trust subject to IRS Form 3520 penalties. The case arose in the ...

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 ...

A Foreign Trust can be a legitimate instrument for US Taxpayers that may have family members in foreign jurisdictions, have foreign business interests or are the beneficiaries of trusts created in ...

United States citizens and residents[i] are subject to federal income tax on their worldwide income. For example, even if a United States citizen permanently relocates to a foreign country, he or she ...

A $1 million gift from a generous European grandmother to her doting U.S. grandson could result in a fine of $250,000 if they are not careful. Gifting sounds nice in theory, but it can be complicated ...

As many readers may know, Joseph Wilson (“Mr. Wilson”) was the settlor, tax owner, and beneficiary of a foreign trust. By virtue thereof, Mr. Wilson, as a U.S. citizen, had the requirement to file IRS ...