Tag: foreign

Feb

The Tax Court Reminds Foreign Corporations of the Disastrous Consequences of Failing to File Forms 1120-F U.S. Income Tax Returns

By Andreozzi Bluestein LLP Comments are Off 1120-F, Corporation, Failure to File, foreign, I.R.C. § 882(c)(2), tax, Tax Court

By: Heather L. Marello, Esq. I.R.C. § 6012(a)(2) imposes an income tax return filing requirement on “every corporation subject to taxation under subtitle A.” The Treasury Regulations clarify that a foreign corporation is not exempt from U.S. taxation if it is engaged in a U.S. trade or business, even if it has no effectively connected U.S. income or its income

Jan

FBAR Penalties – The Government’s Coin-Flip Burden of Proof on Willfulness

By Andreozzi Bluestein LLP Comments are Off account, bank, burden, evidence, FBAR, foreign, fraud, IRS, penalties, preponderance, proof, reporting, tax, willfullness

By: Heather L. Marello, Esq. The Bank Secrecy Act of 1970, Pub. L. 91-507, 84 Stat 114 (Oct. 26, 1970), addressed the government’s desire to monitor the use of foreign bank accounts for illegal activities by authorizing the Secretary of the Treasury to require U.S. citizens, residents, and others to “keep records, file reports, or keep records and file reports,

Tag: foreign

The Tax Court Reminds Foreign Corporations of the Disastrous Consequences of Failing to File Forms 1120-F U.S. Income Tax Returns

FBAR Penalties – The Government’s Coin-Flip Burden of Proof on Willfulness

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