November 25, 2023

Soon after the Tax Cuts and Jobs Act was enacted in 2017, the problems caused by the repeal of section 958(b)(4), commonly referred to as a limitation on the downward attribution of stock ownership from foreign to U.S. persons, became increasingly apparent.  Defining Key Terms For Understanding the Attribution Rules and Form 5471 U.S. Person Only U.S. […]

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