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 ...
The IRS continues to aggressively enforce certain foreign information return obligations. In many cases, these enforcement efforts are automatic—that is, the agency simply imposes the applicable ...
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 ...
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