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By: Lou Carlow On February 1, 2018 the Commissioner of Internal Revenue, Large Business and International Division (LB&I) issued a memorandum providing guidelines for handling delinquent Forms 1120-F and requests for waivers pursuant to Treas. Reg 1.882-4(a)(3)(ii), that states “No one involved in a compliance function should accept as filed a delinquent Form 1120-F from a taxpayer or discuss in
By: Lou Carlow The IRS has identified the failure to file Forms 1120-F as the most recent front for its enhanced campaign to enforce compliance. This campaign sends a clear message to foreign businesses with a U.S. business nexus – comply or beware: Foreign companies doing business in the U.S. are often required to file Form 1120-F. LB&I has data