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RESCINDING AN ENTITY CLASSIFICATION (CHECK-THE-BOX) ELECTION

Mar 31, 2025

In some instances, modifying the U.S. tax classification of your company is a good way to reduce your overall U.S. tax burden without upsetting your local tax position.

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SUPREME COURT RULES ON CONSTITUTIONALITY OF TRANSITION TAX

Aug 26, 2024

In this week’s blog, we discuss a recent Supreme Court decision upholding the constitutionality of the Section 965 transition tax, as well as the impact the decision could have on current filers, particularly those catching up using the Streamlined Procedures.

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Circuit Court Reverses Taxpayer-Friendly Decision on Form 5471 Penalties

May 20, 2024

In this week’s blog, we review the D.C. Circuits Court’s reversal of the Farhy decision, a surprising case from last year holding that the IRS lacks the statutory authority to assess certain international return penalties.

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RESCINDING AN ENTITY CLASSIFICATION (CHECK-THE-BOX) ELECTION

SUPREME COURT RULES ON CONSTITUTIONALITY OF TRANSITION TAX

Circuit Court Reverses Taxpayer-Friendly Decision on Form 5471 Penalties

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