The Supreme Court recently ruled in Bittner vs. United States that federal law prescribes that maximum penalties for the non-willful failure to file a report are calculated per report, not per account. In Bittner, the Court was tasked with interpreting the…
After the presidential election, some citizens planned on renouncing their citizenship and moving abroad to Canada, or elsewhere. It would be interesting to survey those who stated this proposition to see if they followed through on their promise (or threat).…
I.R.C. § 6038 requires U.S. taxpayers to file Form 5471 (Information Return of U.S. Persons With Respect to Certain Foreign Corporations) with their tax returns. The reporting requirements of § 6038, as well as § 6046, require Form 5471 to…
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