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November 25, 2023

Repeal of the Limitation on Downward Attribution, Form 5471 and Safe Harbors from Rev Proc 2019-40

 Update from the OBBB in 2025   The cross-border tax community was alarmed when section 958(b)(4) was repealed by the Tax Cuts and Jobs Act in December 2017. We were equally relieved in July 2025 when it was reinstated by the One Big Beautiful Bill Act (P.L. 119-21), along with the enactment of new […]

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Delinquent International Information Return Submission Procedures – The Ultimate Guide

What do I do if I have a delinquent international information return? Taxpayers who have identified the need to file delinquent international information returns who are not under a civil examination or a criminal investigation by the IRS and have not already been contacted by the IRS about the delinquent information returns should file the

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