Application of Offshore Penalty to Business Ownership Interests
In another essay, I previously discussed the possible inclusion of the business ownership interests in the calculation of the OVDP (2012 Offshore Voluntary Disclosure [...]
IRS Form 8938 and Revised Form 8621 Filing Requirements Under Notice 2011-55
The IRS recently released Notice 2011-55, partially suspending certain Foreign Account Tax Compliance Act (“FATCA”) information reporting requirements until Form 8938, (Statement of Specified [...]