THE NEW REGULATIONS EXPAND THE FILING REQUIREMENTS FOR FORM 5472 TO INCLUDE DISREGARDED ENTITIES WITH FOREIGN OWNERS WHEN THERE ARE CERTAIN REPORTABLE TRANSACTIONS. If a non-U.S. person (individual or corporation)...more
The proposed reforms are a welcome change, specifically as they relate to lookback periods, electronic filing and limited compliance reviews. As a result of what some might view as a scathing decision by the U.S....more