IRS 2013 Budget Proposal Emphasizes International Tax Enforcement
Every year, the President has to submit a budget request to U.S. Congress for federal agencies, including the Internal Revenue Service. In February of [...]
Final Regulations and Guidance Issued on Reporting Interest Paid to Nonresident Aliens under FATCA
The Foreign Account Tax Compliance Act (FATCA), was enacted in 2010 as part of the Hiring Incentives to Restore Employment (HIRE) Act, and mandates [...]
IRS Classification of Foreign Entities: “Per Se” Foreign Corporations
For the U.S. tax compliance purposes, it is very important to properly classify foreign business entities, because there are special IRS requirements associated with [...]
Form 5472 Penalties
In a previous article, we covered the basics of the IRS Form 5472. In this article we will explain the penalties that may apply [...]